Anti-Bribery Policy

1              Policy Statement – Anti Bribery

Bribery is a criminal offence. We do not, and will not, pay bribes or offer improper inducements to anyone for any purpose, nor do we or will we, accept bribes or improper inducements.

To use a third party as a conduit to channel bribes to others is a criminal offence. We do not, and will not, engage indirectly in or otherwise encourage bribery.

We are committed to the prevention, deterrence and detection of bribery. We have zero-tolerance towards bribery. We aim to maintain anti-bribery compliance “business as usual”, rather than as a one-off exercise.

2              Bribery

Is an inducement or reward offered, promised or provided to gain personal, commercial, regulatory or contractual advantage. It is unacceptable to:

• Give, promise to give, or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given
• Give, promise to give, or offer a payment, gift or hospitality to a government official, agent or representative to “facilitate” pr expedite a routine procedure
• Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them
• Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return
• Retaliate against or threaten a person who has refused to commit a bribery offence or who has raised concerns under this policy
• Engage in activity in breach of this policy

Note that the following are not considered acts of bribery

• Providing genuine business hospitality
• Carrying out proportionate and reasonable promotional activities

3              Objective and Scope of this policy

This policy provides a coherent and consistent framework to enable Quality Heating Services (QHS) employees to understand and implement arrangements enabling compliance. In conjunction with related policies and key documents it will also enable employees to identify and effectively report a potential breach.

We require that all staff, including those permanently employed, temporary agency staff and contractors:

• Act honestly and with integrity at all times and to safeguard the organisation’s resources for which they are responsible
• Comply with the spirit, as well as the letter, of the laws and regulations of all jurisdictions in which the Company operates, in respect of the lawful and responsible conduct of activities

This policy applies to all of the company’s activities. For partners, joint ventures and suppliers, we will seek to promote the adoption of policies consistent with the principles set out in this policy.

Within the Company, the responsibility to control the risk of bribery occurring resides at all levels, it does not rest solely within assurance functions, but in all business units and corporate functions.

This policy covers all staff, including all levels and grades, those permanently employed, temporary agency staff, contractors, agents, volunteers and consultants.

4              General Principles

• We will carry out our business fairly, honestly and openly
• We will not make bribes, nor will we condone the offering of bribes on our behalf, so as to gain a business advantage
• We will not accept bribes, nor will we agree to them being accepted on our behalf in order to influence business
• We will keep to these principles even when it becomes difficult
• We will avoid doing business with others who do not accept our values and who may harm our reputation
• We will set out our processes for avoiding direct or indirect bribery, and keeping to and supporting our values

5              Procedures

5.1          Risk Assessments

We will analyse which specific areas pose the greatest risks from bribery, and then design and implement the work accordingly.

5.2          Gifts and Hospitality

We prohibit the offer or receipt of gifts, hospitality or expenses whenever they could affect or be perceived to affect the outcome of business transactions and are not reasonable and bona fide.

5.3          Training

Directors, Managers and relevant employees shall receive appropriate training on these policies and procedures.

5.4          Charitable Donations

• We shall ensure that charitable donations and sponsorships are not used as a subterfuge for bribery
• We shall document all charitable contributions made, with this being reviewed for appropriateness on a timely basis

5.5          Raising Concern and Guidance (“Whistle-blowing”)

We will rely on employees to raise concerns about Bribery as early as possible. To this end, we will provide secure and accessible channels through which employees and others will feel able to raise concerns and report violations in confidence and without risk of reprisal.

5.6          Monitoring

We will review and update our anti-bribery policy and procedures annually.

5.7          Internal Controls

• We shall maintain for inspection accurate books and records that properly and fairly document all financial transactions
• We shall not maintain off the books accounts