Anti-Bribery and Anti-Corruption Policy

Certified management system ISO 9001:2015
DI 128 Issue 1 15/04/19

1. WHAT DOES THIS POLICY COVER

1.1 This Anti-Bribery policy exists to set out the responsibilities of Skytec Aviation Ltd and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.

1.2 It also exists to act as a source of information and guidance for those working for Skytec Aviation Ltd. It helps them recognise and deal with bribery and corruption issues as well as understanding their responsibilities.

2. POLICY STATEMENT

2.1 Skytec Aviation Ltd is commited to conduct business in an ethical and honest manner and is commited to implementing and supporting systems that ensure bribery is prevented. Skytec Aviation Ltd has zero-tolerance for bribery and corruption activities. We are commited to acting professionally, fairly and with integrity in all business dealings and relationships, wherever we operate.

2.2 Skytec Aviation Ltd will constantly uphold all laws related to anti-bribery and corruption in all jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.

2.3 Skytec Aviation Ltd recognises that bribery and corruption is punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities we may be subject to an unlimited fine and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

3. WHO IS COVERED BY THIS POLICY

3.1 This Anti-Bribery Policy applies to all employees (whether temporary, fixed-term or permanent), consultants, contractors, trainees, casual workers, agency staff, agents, sponsors or any other person or persons associated with us (including third parties) no matter where they are located (within or outside the UK). The policy also applies to Officers, Trustees and board members at any level.

3.2 In the context of this policy, third party refers to any individual or organisation our company meets or works with. It refers to actual and potential clients, customers, suppliers, distributers, business contacts, agents, advisers and government and public bodies – this includes their advisors, representatives and officials, politicians and public parties.

4. DEFINITION OF BRIBERY

4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting or soliciting something of value or of an advantage so to induce or influence an action or decision.

4.2 A bribe refers to any inducement, reward or object/item of value offered to another individual in order to gain commercial, contractual, regulatory or personal advantage.

4.3 Bribery is not limited to the act of offering the bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above) or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company compliance department (Croner +44 (0)808 145 3378).

5. WHAT IS AND WHAT IS NOT ACCEPTABLE

5.1 This section of the policy refers to 4 areas:
- Gifts and hospitality;
- Facilitation payments;
- Political contributions;
- Charitable contributions.

5.2 Gifts and hospitality
Skytec Aviation Ltd accepts normal and appropriate gestures of hospitality and goodwill (whether given to or received from third parties) so long as the giving or receiving of gifts meets the following requirements:
a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of business or a business advantage or as an explicit or implicit exchange for favour or benefit.
b. It is not made with the suggestion that a return favour is expected.
c. It is in compliance with local law.
d. It is given in the name of the company, not in an individuals name.
e. It does not include cash or cash equivalent (e.g. a voucher or gift certificate).
f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a thank you to a company for helping with a large project on completion).
g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
h. It is given/received openly, not secretly.
i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
j. It is not above a certain excessive value, as pre-determined by the company director.
k. It is not offer to, or accepted from, a government official or representative or politician or political party without the prior approval of the company director.

5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion or culture who may take offence), the gift may be accepted so long as it is declared to the company director who will assess the circumstances.

5.4 Skytec Aviation Ltd recognises the practice of giving and receiving business gifts varies between countries, regions, cultures and religions so definitions of what is acceptable and not acceptable will differ for each.

5.5 As good practice, gifts given and received should always be disclosed to the managing director to assess for compliance. Gifts from suppliers should always be disclosed.

5.6 The intention behind a gift being given or received should always be considered. If there is any uncertainty, the advice of the managing director or Croner compliance department should be sought.

5.7 Facilitation payments or kickbacks
Skytec Aviation Ltd does not accept and does not make any type of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

5.8 Skytec Aviation Ltd does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

5.9 Skytec Aviation Ltd recognises that, despite our strict policy on facilitatin payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family's personal security at risk. Under these circumstances, the following steps must be taken:
a. Keep the amount to the minimum;
b. Ask for a receipt detailing the amount and reason for payment;
c. Create a record concerning the payment;
d. Report the incident to your line manager.

5.10 Political contributions
Skytec Aviation Ltd will not make donations, whether in cash, kind or by any other means, to support political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

5.11 Charitable contributions
Skytec Aviation Ltd accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate or conceal acts of bribery.

5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices and that donations are not offered/made without the approval of the managing director.

6. EMPLOYEE RESPONSIBILITIES

6.1 As an employee of Skytec Aviation Ltd, you must ensure that you read, understand and comply with the information contained within this policy and with any training or other anti-bribery and corruption information you are given.

6.2 All employees and those under our control are equally responsible for the prevention, detection and reporting of bribery and other forms of corruption. They are required to avoid any activity that could lead to, or imply, a breach of this Anti-Bribery Policy.

6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify your line manager or managing director or Croner (+44 (0)808 145 3378).

6.4 If any employee breaches this policy, they will face gross misconduct disciplinary action up to and including dismissal.

7. WHAT HAPPENS IF I NEED TO RAISE A CONCERN?

7.1 This section of the policy covers 3 areas:
a. How to raise a concern;
b. What to do if you are a victim of bribery or corruption;
c. Protection.

7.2 How to raise a concern.
If you suspect there is an instance of bribery or corrupt activities occurring in relation to Skytec Aviation Ltd, you are encouraged to raise your concerns as early a stage as possible. If you are uncertain about whether an action or behaviour can be considered bribery or corruption, you should speak to your line manager, the managing director or Croner.

7.3 Skytec Aviation Ltd will ensure that any employee can vocalise their concerns confidentially and those concerns will be taken seriously and investigated.

7.4 What to do if you are a victim of bribery or corruption.
You must tell your line manager or managing director as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may have been bribed or asked to make a bribe in the near future or if you have reason to believe that you are the victim of another corrupt activity.

7.5 Protection If you refuse to accept the offer of a bribe or you report a concern relating to certain act(s) of bribery or corruption, Skytec Aviation Ltd understands that you may feel worried about potential repercussions. Skytec Aviation Ltd will support anyone who raises concerns in good faith under this policy, even if the investigation finds they were mistaken.

7.6 Skytec Aviation Ltd will ensure that no one suffers any detrimental treatment as a result of refusing to accept the offer of a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

7.7 Detrimental treatment refers to dismissal, disciplinary action, treats or unfavourable treatment in the relation to the concern the individual raised.

7.8 If you have any reason to believe you have been subject to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your manager or the managing director immediately.

8. TRAINING AND COMMUNICATION

8.1 Skytec Aviation Ltd will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy and will be asked annually to formally accept that they will comply with this policy.

8.2 Skytec Aviation Ltd's Anti-Bribery and Corruption Policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors and any third parties at the outset of business relations and as appropriate thereafter.

8.3 Skytec Aviation Ltd will provide relevant anti-bribery and corruption training to employees where we feel their knowledge of how to comply with the Bribery Act is required. As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities.

9. RECORD KEEPING

9.1 Skytec Aviation Ltd will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence of all payments made. We will declare and keep written records of the amount and reason for hospitality and gifts accepted and given and understand that gifts and acts of hospitality are subject to managerial review.

10. MONITORING AND REVIEWING

10.1 Skytec Aviation Ltd's managing director is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy and effectiveness.

10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure effectiveness in practice.

10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy and if they have any suggestions on how it may be improved. Feedback of this nature should be addressed to their line manager.

10.4 This policy does not form part of the employee's contract of employment and Skytec Aviation Ltd may amend it at any time to improve its effectiveness at combatting bribery and corruption.