Anti Bribery, Corruption and Whistle Blowing Policy

1. Introduction

1.1. This Statement sets out the policy of the Cole Contractors Limited (The Company) in respect of any employee, self-employed person and contractor under our control, as it relates to Anti Bribery, Corruption and whistle blowing.

1.2. Provided that persons referred to in 1.1 above adhere to the provisions contained within this policy, they will normally be considered to have demonstrated compliance with their conditions of employment or contract.

1.3. All persons referred to in 1.1 above are to be made aware of the contents of this Policy and become familiar with the conditions laid down therein.

1.4. A copy of this policy statement will be held in the reception area of our offices and be made freely available for inspection by any person having reason to examine it.

2. Policy

2.1. All employees have a responsibility to act in good faith and to promote the good name and effectiveness of their employer. You are expected to be trustworthy and to conduct yourself reasonably at all times. No employee is permitted to give press or other media interviews or assist with or be involved in the publication of any article relating to the business affairs of the organisation or in relation to the organisation’s intellectual property, without prior consent from the Directors.

2.2. You must not engage in any activity which may prejudice the performance of your duties as an employee of Cole Contractors Limited. If you find yourself in a situation where there is a conflict or potential conflict of interest between your outside activities and your duties as an employee of Cole Contractors Limited, you must immediately report the matter to your line manager.

Generally, a conflict of interests exists when an employee is involved in an activity:

• Which provides products or services directly to, or purchase products or services from Cole Contractors Limited
• Which subjects the employee to unreasonable time demands that prevent the employee form devoting proper attention to his or her responsibilities to Cole Contractors Limited
• Which is so operated that the employee’s involvement with the outside business activity will reflect adversely on Cole Contractors Limited.

Should you be in doubt as to whether an activity involves a conflict, you should discuss the situation
with your manager.

3. Bribery and other Corrupt Behaviour

3.1. The Company has a strict anti-bribery and corruption policy in line with the Bribery Act (2010). A bribe is defined as: giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so

3.2. If you bribe (or attempt to bribe) another person, intending either to obtain or retain business for the company, or to obtain or retain an advantage in the conduct of the company’s business this will be considered gross misconduct. Similarly accepting or allowing another person to accept a bribe will be considered gross misconduct. In these circumstances you will be subject to formal investigation under the Company’s disciplinary procedures, and disciplinary action up to and including dismissal may be applied.

4. Whistleblowing

4.1. If you have any concerns about Cole Contractors Limited, and its work, these should be raised with your line manager and/or the Directors. All employees are protected by the Public Disclosure Act.

5. Implementing the Policy

5.1. In order to put this policy into practice in the day-to-day operation of the Company, we will (as appropriate):-

• Make the policy available to all employees and others under our control.
• Provide training and guidance for key decision makers such as managers and supervisory staff and those involved in personnel and management practices.
• Monitor the existing workforce in respect of the application and effects of the policy.
• Review this policy on a regular basis (at least annually).

5.2. Should any person suffer any problems or difficulties in respect of this policy, or should they have reason to believe that a colleague may be experiencing such difficulties, they may approach the signatory of this policy statement, who will at all times treat any information provided in complete confidence and take such measures as are deemed necessary.