Zero tolerance for bribery and corrupt activity.

1. What does the European Diplomats policy cover?

1.1 This anti-bribery policy exists to set out the responsibilities of European Diplomats and those who work for us in regard 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 European Diplomats. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

2. Policy statement

2.1 European Diplomats is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. European Diplomats has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly and with integrity in all business dealings and relationships, wherever in the country we operate.

2.2 European Diplomats will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the EU, including the German Act on Administrative Offences, in regard to our conduct both at home and abroad.

2.3 European Diplomats recognises that bribery and corruption are 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 subjected to an unlimited fine, be excluded from tendering for public contracts 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 the policy?

3.1 This anti-bribery policy applies to all employees, whether temporary, fixed term or permanent, consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us, including third parties, or any of our subsidiaries or their employees, no matter where they are located. The policy also applies to officers, trustees, board and committee members at any level.

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

3.3 Any arrangements our company makes with a third party are subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

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 to induce or influence an action or decision.

4.2 A bribe refers to any inducement, reward or 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 a bribe. If an individual is on the receiving end of a bribe and accepts it, they are also breaking the law.

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether directly, passively 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. 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’s compliance manager.

5. What is and what is not acceptable

5.1 This section of the policy refers to four areas: gifts and hospitality, facilitation payments, political contributions and charitable contributions.

Gifts and hospitality

5.2 European Diplomats 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:

• 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 favours or benefits.
• It is not made with the suggestion that a return favour is expected.
• It complies with local law.
• It is given in the name of the company, not in an individual’s name.
• It does not include cash or a cash equivalent, such as a voucher or gift certificate.
• It is appropriate for the circumstances.
• It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
• It is given or received openly, not secretly.
• It is not selectively given to a key, influential person with the intention of directly influencing them.
• It is not above an excessive value as determined by the company’s compliance manager, usually in excess of €100.
• It is not offered to, or accepted from, a government official, representative, politician or political party without prior approval from the company’s compliance manager.

5.3 Where it is inappropriate to decline the offer of a gift, for example when meeting with an individual of a particular religion or culture who may take offence, the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.

5.4 European Diplomats recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures and religions, so definitions of what is acceptable will inevitably differ.

5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. 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, advice from the compliance manager should be sought.

Facilitation payments and kickbacks

5.7 European Diplomats does not accept and will not make any form of facilitation payment. We recognise that facilitation payments are a form of bribery involving the expediting or facilitating of the performance of a public official for a routine governmental action.

5.8 European Diplomats 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 European Diplomats recognises that, despite our strict policy, employees may face a situation where avoiding a facilitation payment or kickback may put their or their family’s personal security at risk. Under these circumstances, the following steps must be taken:

• Keep any amount to the minimum.
• Ask for a receipt detailing the amount and reason for the payment.
• Create a record concerning the payment.
• Report the incident to your line manager.

Political contributions

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

Charitable contributions

5.11 European Diplomats accepts and encourages the act of donating to charities, whether through services, knowledge, time or direct financial contributions, and agrees to disclose all charitable contributions it makes.

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

5.13 We will ensure that all charitable donations are legal and ethical under local laws and practices, and that donations are not offered or made without the approval of the compliance manager.

6. Employee responsibilities

6.1 As an employee of European Diplomats, 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 activities that could lead to, or imply, a breach of this 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 and may breach this policy, you must notify the compliance manager.

6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. European Diplomats has the right to terminate a contractual relationship with an employee if they breach this policy.

7. Raising a concern

7.1 This section covers how to raise a concern, what to do if you are a victim of bribery or corruption, and protection.

7.2 If you suspect that bribery or corrupt activity is occurring in relation to European Diplomats, you are encouraged to raise your concerns at the earliest possible stage. If you are uncertain whether an action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director or the Head of Governance and Legal.

7.3 European Diplomats will familiarise employees with its whistleblowing procedures so employees can raise concerns swiftly and confidentially.

7.4 You must tell your compliance manager as soon as possible if you are offered a bribe, asked to make one, suspect that you may be bribed or asked to make a bribe, or have reason to believe that you are a victim of another corrupt activity.

7.5 European Diplomats will support anyone who raises concerns in good faith under this policy, even if an investigation finds they were mistaken.

7.6 European Diplomats will ensure that no one suffers detrimental treatment as a result of refusing to accept or offer a bribe or because they reported a concern relating to potential bribery or corruption.

7.7 Detrimental treatment includes dismissal, disciplinary action, threats or unfavourable treatment in relation to the concern raised.

7.8 If you believe you have been subjected to unjust treatment as a result of raising a concern or refusing to accept a bribe, you should inform your line manager or the compliance manager immediately.

8. Training and communication

8.1 European Diplomats will provide training on this policy as part of the induction process for 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 it.

8.2 European Diplomats’ anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to suppliers, contractors, business partners and third parties at the outset of business relations, and as appropriate thereafter.

8.3 European Diplomats will provide relevant anti-bribery and corruption training to employees where we feel their knowledge of compliance needs to be enhanced.

9. Record keeping

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

10. Monitoring and reviewing

10.1 European Diplomats’ compliance manager is responsible for monitoring the effectiveness of this policy and will review its implementation 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 that they are effective in practice.

10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer feedback on this policy if they have suggestions for improvement. Feedback should be addressed to the compliance manager.

10.4 This policy does not form part of an employee’s contract of employment and European Diplomats may amend it at any time to improve its effectiveness in combating bribery and corruption.