Gifts and Hospitality Policy

1 Introduction

1.1 The Company runs its business[es] with integrity. All of us must work together to ensure that they remain untainted by bribery or corruption. This policy is integral to that effort and we are all, the board and all employees of the Company, bound by it.

1.2 This policy covers the offer or receipt of gifts, hospitality or expenses to ensure that any legitimate expenditure is recorded and does not improperly affect the outcome of procurement, application or any other business transaction.

2 Offer and receipt of gifts and hospitality

2.1 The Company forbids any officer or employee of the Company from soliciting any gift or hospitality in the course of his or her employment.

2.2 The Company forbids any officer or employee of the Company from offering or receiving from any person or organisation who has had, has or may have any influence over the business of the Company any gift or hospitality which is unduly lavish or extravagant or otherwise inappropriate, or which could be seen as an inducement or reward for any preferential treatment. The Company regards the following to be inappropriate (the list is not exhaustive):