Knaresborough Engineering:

Anti-Bribery & Anti-Corruption Policy

1. Policy Statement

Knaresborough Engineering (Yorkshire) Limited is committed to conducting all of its business activities in an honest, ethical, and transparent manner. This Anti-Bribery and Anti-Corruption Policy is designed to ensure that we uphold the highest standards of integrity in all business dealings and relationships, both locally and internationally. We are fully compliant with the UK Bribery Act 2010 and any other relevant legislation.

Knaresborough Engineering has zero tolerance for any form of bribery or corruption. Any breach of this policy could result in severe penalties, including disciplinary action, termination of employment, and criminal sanctions.

2. Scope

This policy applies to all employees of Knaresborough Engineering (whether permanent, temporary, fixed- term, or agency), consultants, contractors, trainees, and any third-party representatives or partners associated with us. This includes clients, suppliers, and public officials across all regions where we operate.

3. Definition of Bribery

Bribery refers to offering, giving, receiving, or soliciting something of value in exchange for influencing the actions of an individual or an organisation. This includes actions intended to obtain or retain business, secure an improper advantage, or influence a decision.

Bribery can take many forms, including but not limited to:

– Cash payments

– Gifts, hospitality, or entertainment beyond reasonable and lawful limits

– Favours or preferential treatment

4. What Is and Is Not Acceptable

4.1 Gifts and Hospitality

Knaresborough Engineering recognises that offering or receiving modest gifts and hospitality may sometimes be appropriate in building business relationships. However, it must always be:

– Given in a transparent, lawful, and ethical manner.

– Not intended to improperly influence business decisions.

– Appropriate in terms of value and context (gifts exceeding £100 must be approved by the compliance officer).

– Recorded and disclosed to the compliance officer.

4.2 Facilitation Payments

Facilitation payments (small payments made to expedite routine tasks) are considered bribes under this policy and are strictly prohibited, even if local customs may suggest otherwise.

4.3 Political and Charitable Contributions

Knaresborough Engineering will not make political donations, whether in cash or other means, as it could be perceived as an attempt to gain an improper advantage. Charitable donations are allowed only if they are not used to conceal corrupt practices and are approved by the compliance manager.

5. Employee Responsibilities

All employees are responsible for adhering to this policy and must avoid any activity that could lead to a breach of anti-bribery laws. If you are unsure about any aspect of the policy, it is essential to seek advice from the compliance manager.

Employees must immediately report any suspicion of bribery or corruption. Failing to report a known or suspected breach of this policy will result in disciplinary action.

6. How to Raise a Concern

If you suspect any instance of bribery or corruption, you must report it to the compliance officer, Ms Debbie Quick or your line manager. Knaresborough Engineering will treat all reports in confidence and ensure that no individual suffers detrimental treatment for raising concerns in good faith.

This anti-bribery & anti-corruption policy will be reviewed and updated regularly.

Robert Waller
Managing Partner. Director
Knaresborough Engineering (Yorkshire) Limited — March 2023