Anti Bribery and Corruption Compliance Policy

Claranet Limited is committed to compliance with all Anti Bribery and Corruption Laws to which it is subject including but not limited to the UK Bribery Act 2010. Claranet is committed to running a professional business free from discreditable behaviour of any kind. It is particularly committed to Principle 2 of the Guidance given under the Bribery Act by the Ministry of Justice (MOJ), that is, to prevent bribery by persons associated with it.

Claranet has followed the MOJ Guidance with regard to the Bribery Act 2010.

Compliance Policy, Practices and Procedures

This document (“the Policy”) has been approved by the Directors of Claranet Limited and describes the policy of Claranet together with the practices and procedures to be followed in order to comply with section 7 of the Bribery Act 2010. This policy is applicable to all directors, employees, agents, resellers, contractors and subcontractors of Claranet Limited and is incorporated in to all respective contracts pertaining to the aforementioned.

In order to prevent the unwitting engagement in behaviour which might raise the suspicion of bribery and to prevent any associated person purporting to act on its behalf in a manner that brings suspicion on Claranet and its’ employees, the following measures have been adopted as appropriate and proportionate to the risks it faces. They will be enforced by their dissemination, regular training and disciplinary measures. Any resources that are required to implement any compliance measures are to be made available.

Management

  1. The responsibility for compliance of this policy rests with the top level of management. The Directors will exercise oversight, make assessments of risk, deal with decisions where potential for bribery exists, receive and investigate reports of bribery and supervise the measures put in place to prevent bribery.
  2. The daily overall responsibility for the compliance with the Bribery Act and the implementation of the policy rests with the Senior Commercial Manager, the Finance Director and the Director of Human Resources. They are to be consulted on any matter where the possibility of unlawful acts could arise.
  3. It shall be a condition of the contract of employment of all employees that they shall at all times observe the requirements of this policy.
  4. The Directors and employees shall report any attempt at bribery which comes to their attention, whether it consists of an approach to one of them or an act done by an associated third party. In the first instance the report should be made to the Senior Commercial Manager, the Finance Director and the Director of Human Resources.
  5. Under no circumstances should a person who reports a suspicion of bribery be subject to victimisation for making a bona fide report, whether or not the suspicion turns out to be justified.

Assessment of Risk

Claranet is an ethical company and is governed by a strict code of conduct. Our employees act upon instructions and are chosen for their integrity as well as ability. As such the general assessment of the risk of committing an offence under the Act is very low.

The risk of falling foul of a section 6 offence, of bribing a foreign official or of extra-territorial offences does not arise.

However:

  1. In relation to occasions on which hospitality is offered or accepted by Directors or employees, issues may arise as to the line between a proper public relations exercise and an intention to induce improper performance of a relevant function;
  2. In relation to awarding of contracts for services Claranet Limited has provisions for competitive tendering in place. However, as an additional requirement and as a requirement in awarding contracts which are not required to go out to tender, an issue of bribery might arise.
  3. In relation to charitable and political donations care should be exercised to avoid the suggestion of soliciting favours.

The assessment of Claranet's exposure to external and internal risks of bribery will be assessed annually.

Hospitality

In relation to hospitality, promotional expenditure which seeks to improve the image of Claranet, to establish cordial and professional relationships and to maintain them is not unlawful if it is reasonable and proportional.

In order to make an assessment of any particular hospitality event which is to be offered to a client or prospective client the Marketing Director will have to be supplied with information. This will include the cost and nature of the hospitality, the name and details of the person to be entertained and the purpose of the event. He will be required to approve the event or make suggestions for modifying it.

In the event that a Director or employee is invited to an event, a similar procedure should be followed.

Communication

A copy of this policy will be available on the public area of the website. Reference will be made to it in all documents provided to clients, contracts with suppliers and agents.

Training

Staff employed by Claranet will be required to undergo regular training in the terms of the Bribery Act and the requirements described in this document. It shall be a term of the contracts of employment that such training should be undertaken.

A copy of the up to date guidance given by the Ministry of Justice under section 9 of the Act will be available on the intranet for consultation.

Any member of staff is able to approach senior management in absolute confidence in order to receive advice as to their conduct or to report a matter to concern which relates to bribery.

Review and Amendments

In drafting this policy regard was had to the guidance issued under section 9 of the Bribery Act. Claranet will keep this policy under review and make amendments to it as appropriate and in the light of further guidance issued under section 9 of the Bribery Act.