Anti-Bribery Policy

Message from the Chief Executive

At Go Greena we are committed to doing the right thing, the right way. We expect our company, its owners, managers and staff to engage in the highest standard of behaviour.

This is more important than ever because of the strict new rules brought in by the new Bribery Act. We operate a zero tolerance approach to the making or receiving of bribes or corrupt payments, in any form. This type of conduct is absolutely prohibited whether committed by employees or anyone else acting on the Company’s behalf.

This policy sets out what is and is not acceptable in general terms, but if you are in any doubt as to whether any conduct could amount to bribery, the matter should be referred to the company’s Operations Director.

It is essential that you read and comply with this policy.

Charles Cook

Managing Director

Statement from the Operations Director

As Operations Director within Go Greena it is my responsibility to act a chief compliance officer in respect of bribery and corruption matters.

I have overall responsibility for our compliance in this area. The Company considers bribery and corruption risks as a standing item on its agenda. The Board is also updated on this topic on a regular basis and provided with ad hoc updates when necessary.

Our Legal Department advises the Company on the legal aspects of compliance.

Barnaby Cook

Operations Director & Head of Corporate Governance

1. About This Policy

2. Who Must Comply?

  • 2.1. The Go Greena Anti-Bribery policy is mandatory for all Go Greena employees, agents, intermediaries, consultants, distributors, sub-contractors and suppliers (“Business Partners”).
  • 2.2. It is important that you take the time to read and comply with this Policy. The prevention, detection and reporting of any bribery in any form is the responsibility of all employees across the Go Greena company and all individuals and entities over which Go Greena has control. Appropriate confidential channels for employees and Business Partners are in place to report any suspicion of bribery, these are described later in this Policy.
  • 2.3. Any failure to comply with this Policy will be treated seriously and may result in disciplinary action.

3. How Do You Comply?

  • 3.1. You must read and abide by the terms of this Policy.
  • 3.2. You may also be required to provide written confirmation that you will comply with this policy, by signing up via the Code of Ethics.

4. What Happens If You Don’t Comply?

  • 4.1. For Employees: Any act of bribery, in whatever form is unacceptable. We will consider taking disciplinary action against anyone who fails to comply with the anti-bribery policy up to and including dismissal. Failure to comply with this policy may also leave you open to a criminal prosecution under the Act. An offence under the Act can result in a fine and/or up to a maximum of 10 years imprisonment.
  • 4.2. For Go Greena: A breach of this Policy by an employee or business partner could result in the Company breaching the Act. An offence under the Act can result in the business being fined and would likely lead to negative publicity and serious damage to the reputation of the Go Greena brand.

5. What You Cannot Do

  • 5.1. Prohibited Conduct: The following conduct is absolutely prohibited under this Policy:
    • 5.1.1. making unofficial payments to officials in order to obtain any permission, permit or stamp particularly in connection with importing or exporting goods;
    • 5.1.2. appointing any third party or supplier to act on behalf of Go Greena who you know or have good reason to believe to have engaged in any corrupt or unlawful conduct including any offences under the Act; or
    • 5.1.3. paying any third party for the purposes of being a ‘fixer’ to open doors and make connections for us
  • 5.2. Facilitation payments:
    • 5.2.1. Facilitation payments (‘facilitating’, ‘speed’ ‘back-hander’ or ‘grease’ payments) are any payments, usually small cash payments made to low-level officials, as a bribe to secure or expedite the performance of a routine or necessary action or level of service.
    • 5.2.2. Go Greena employees or Business Partners must never offer, pay, solicit or accept bribes in any form, including facilitation payments. Go Greena employees must report to the Operations Director any instance where a facilitation payment is alleged to have been paid on the Company’s behalf.
    • 5.2.3. Exception: The only exception to paying a facilitation payment is where your life is in danger. If a facilitation payment is made it must be reported Operating Director as soon as reasonably practicable in order that it can be recorded.

6. Due Diligence

  • 6.1. Where there is a significant bribery risk (as explained in more detail at clause 6.2) all employees and Business Partners must consult with the Operations Director in relation to appropriate anti bribery compliance measures before:
    • 6.1.1. Appointing a new supplier; or
    • 6.1.2. Entering into a partnership; or
    • 6.1.3. Appointing an agent to work on the Company’s behalf; or
    • 6.1.4. Entering into a new contract or amending the terms of an existing contract.
  • 6.2. A significant bribery risk will arise if:
    • 6.2.1. the supplier, partner or agent etc is based in a High Risk Jurisdiction
    • 6.2.2. the services being provided involve work being undertaken, directly or indirectly on our behalf, in any High Risk Jurisdiction
    • 6.2.3. the service involves goods passing through borders between High Risk Jurisdiction
    • 6.2.4. the services involve business partners paying fees, taxes or payments on behalf of Go Greena in relation to the import or export of goods.

7. Gifts, Hospitality & Entertainment

  • 7.1. All Go Greena employees are expected to conduct themselves with integrity, impartiality and honesty at all times. Accordingly, all employees are required to follow these rules on Gifts, Hospitality and Entertainment.
  • 7.2. You must maintain a high standard of professionalism and not open yourself up to suspicion of dishonesty or put yourself in a position of conflict between your work and your private interests, Gifts and entertainment given and received as a reward, inducement or encouragement for preferential treatment or inappropriate or dishonest conduct are strictly prohibited. In particular, no gifts, hospitality or entertainment may be given or accepted during a tender process or during contractual negotiations if there is any realistic risk that such gifts or entertainment could influence the outcome of such processes or negotiations.
  • 7.3. It is important that all Go Greena employees’ actions are able to withstand scrutiny and not cause any embarrassment to the Company, yourself or any third party including contracts or suppliers.
  • 7.4. You may accept low value token gifts such as branded pens, stationery and mouse mats produced for the purpose of being given away, if given by an existing supplier. Occasional boxes of confectionery etc may be given to a department as opposed to an individual. Otherwise you must refuse personal gifts such as Christmas, wedding or birthday gifts, including vouchers or cash equivalents, received from partners, suppliers, clients and other third parties.
  • 7.5. Go Greena employees may occasionally receive invitations from suppliers or others to corporate hospitality or entertainment events. Hospitality or entertainment may only be accepted if the entertainment or hospitality is not unduly lavish or extravagant, is attended by personnel from the supplier and the entertainment or hospitality can not be interpreted as a reward, inducement or encouragement.
  • 7.6. All hospitality and entertainment must be recorded in the relevant hospitality and entertainment register on a monthly basis.

8. Reporting Procedure

  • 8.1. Go Greena aims to conduct business with the highest standards of ethics, honesty and integrity and recognises that you have an important role to play in maintaining the aim. Any employee concerned about any form of malpractice, improper action or wrongdoing by the Company its employees or other stakeholders are strongly encouraged to report the matter.
  • 8.2. We believe it is essential to create an environment in which you feel able to raise any matters of genuine concern internally without fear of disciplinary action being taken against you, that you will be taken seriously and that the matters will be investigated appropriately and as far as practicable be kept confidential.
  • 8.3. Go Greena believes that nay employee with knowledge of bribery in any form should not remain silent. We take all matters of malpractice, improper action or wrongdoing very seriously and you are strongly encouraged to raise incidents or behaviours that are not in accordance with the policy, by following the procedure set out below:
    • 8.3.1. Line Manager: In the first instance you should consider raising your concerns with your line manager. He/she has responsibility to listena dn respond to any matter that is of concern to you. Concerns can be raised verbally or in writing. Your line manager will determine whether he/she is able to investigate the concern directly, keeping the Operations Director updated, if appropriate, of progress and its conclusion. It the line manager is unable to resolve the issue, he/she will escalate the concern to the Operations Director, who will manage your concern.
    • 8.3.2. Operations Director: If you feel that you need to raise the issue outside of your immediate working environment, you should contact the Operations Director. He will record the concern and determine the appropriate approach to take in managing any investigation, including whether to appoint an external independent individual to review the matter, or refer it to the appropriate internal or external body.

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