Anti-Bribery and
Corruption Policy

Introduction

Heriot A.V Ltd has a number of fundamental principles and values which it believes are the foundation of sound and fair business practice and as such are important to uphold. One such principle is a zero-tolerance position in relation to bribery and corruption, wherever and in whatever form that it may be encountered. Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action which is illegal or a breach of trust. This document is intended to build on our Ethics Policy and to clearly state the standards required, ensuring conformance to our principles as well as the legal requirements
within the countries in which Heriot Ltd and its subsidiary companies operate.

Heriot A.V Ltd values its reputation for ethical behaviour, financial profitability, and reliability. It recognises
that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its
image and reputation. Its aim therefore is to limit its exposure to bribery and corruption by:

  • Setting out a clear anti-bribery & corruption policy
  • Training all employees so that they can recognise and avoid the use of bribery by themselves and others
  • Encouraging its employees to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately
  • Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution
  • Taking firm and vigorous action against any individual(s) involved in bribery or corruption

What is Bribery?

A bribe does not need to be actual money. It can be any form of advantage, offered, requested, or received. A contract does not need to have been won for a corruption offence to have been committed. Similarly, a recipient does not need to benefit personally from a bribe – it may be the intended beneficiary is a third
party or a company. Finally, bribery can occur in the private as well as the public sector – it is not just about our relationship with public officials.

Policy

Heriot A.V Ltd policy consists of two straightforward rules that all employees and all consultants / agents
must adhere strictly to:

  • Do not offer, promise, or pay bribes
  • Do not request, agree to, or accept bribes

This policy applies to individual employees, customers, suppliers, agents, distributors, consultants or any other people or bodies associated with Heriot A.V

Gifts & Hospitality

Gifts and hospitality can also amount to bribery. Local custom and practice are not a valid defence. The test to be applied in all circumstances is whether the gift or entertainment is reasonable and proportionate. What is the intention of the gift?

Special care must be taken in accepting or giving gifts / entertainment and these are not permitted if it would create a real or perceived conflict of interest. Each business will have in place, its own appropriate guidelines and authority procedures in relations to Gifts & Hospitality to ensure transparency and proportionality.

This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Heriot A.V or of the person or body employing them or whom they represent. This policy is not meant to prohibit the following practices proving they are proportionate and are properly recorded:

  • The giving or receiving of reasonable and appropriate hospitality
  • The giving of a ceremonial gift of nominal value on a festival or at another special time

Facilitation Payments

This policy also prohibits ‘facilitation payments’ which are small unofficial payments for routine governmental action, such as speeding up the unloading of cargo, issuing permits, and other actions of an official, in order to expedite performance of duties which they are already bound to perform. This should be contrasted with recognised ‘fast track’ processes available to all on payment of an official fine.

If you are unsure as to the validity of an official’s request for a payment, the steps below should be followed as far as they are applicable and as far as it is possible for you to do so without putting your personal safety or security at risk:

  • If possible, contact your line manager or supervisor immediately
  • Ask the official for proof of the validity of the fee
  • Request that a receipt be provided confirming the validity of the payment
  • If no proof of validity will be provided, politely decline to make the payment, and explain you cannot make the payment because of company policy and anti-bribery laws
  • If possible, ask to see the official’s supervisor
  • Make a full note of the request, the circumstances and the parties involved
  • At all times remain calm, respectful, and polite

Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to their immediate manager, supervisor or the Company Secretary before Proceeding.

Report Concerns – Employee Responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees throughout the Group. Suitable channels of communication by which employees or others can report confidentially any suspicion of bribery will be maintained and employees may use the confidential hotline to report any suspicions of bribery.

Employees who are suspected of involvement in bribery or corruption will be subject to disciplinary procedure.

The Heriot A.V Managing Director has lead responsibility for this policy implementation within the Company.