Anti-bribery Policy

Summary

The Kimpton Ltd company policy on bribery is as follows:

1. We do not pay bribes
2. We do not accept bribes
3. If in doubt, please refer to the UK Bribery Act 2010
4. Any employee contravening the above will be subject to disciplinary proceeding

Legal obligations

The UK legislation on which this Policy is based is the Bribery Act 2010 and it applies to the Company’s conduct both in the UK and abroad. A bribe is an illegal inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a bribe.

All employees and associated persons are required to:

• Comply with any anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which they might be expected to conduct business
• Act honestly, responsibly and with integrity
• Safeguard and uphold the company’s core values by operating in an ethical, professional and lawful manner at all times.

The giving of business gifts to clients, customers, contractors and suppliers is not prohibited provided the following requirements are met:

• The gift is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage
• It is given in the company’s name, not in the giver’s personal name
• It does not include cash or a cash equivalent (such as gift vouchers)
• It is of an appropriate and reasonable type and value and given at an appropriate time
• It is given openly, not secretly and is approved in advance by a company director

Signed Director:  Richard Kimpton

Dated:  3^rd January 2023

Richard Kimpton