Anti-Corruption and Bribery Policy

It is KRCS policy to conduct all business in an honest and ethical manner. KRCS takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships.

KRCS will uphold all laws relevant to countering bribery and corruption, including the Bribery Act 2010, in respect of conduct both in the UK and overseas.

The purpose of this policy is to:

• Set out KRCS responsibilities, and the responsibilities of those working for or on behalf of KRCS, in observing and upholding its position on bribery and corruption.
• Provide information and guidance on how to recognise and deal with bribery and corruption issues.

It is a criminal offence to offer, promise, give, request or accept a bribe. Individuals found guilty can be punished by imprisonment and/or a fine. An employer that fails to prevent bribery can face an unlimited fine, exclusion from tendering for public contracts and reputational damage.

In this policy, third party means any individual or organisation encountered in the course of work for KRCS, including actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, government and public bodies, their representatives and officials, politicians and political parties.

This policy does not form part of any employee contract of employment and may be amended at any time.

This policy applies to all persons working for KRCS or on its behalf in any capacity, including employees, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, business partners, sponsors and any other associated person, wherever located.

Bribery is offering, promising, giving or accepting any financial or other advantage to induce or reward improper performance, or where acceptance of the advantage would itself be improper.

An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.

A person acts improperly where they act illegally, unethically, contrary to an expectation of good faith or impartiality, or where they abuse a position of trust.

Corruption is the abuse of entrusted power or position for private gain.

Examples

Offering a bribe: offering tickets to a major sporting event to a potential client only if they agree to do business with KRCS could constitute an offence.

Receiving a bribe: accepting a personal benefit from a supplier in return for using influence within KRCS to secure continued business could constitute an offence.

It is not acceptable for you, or someone acting on your behalf, to:

• Give, promise to give or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.
• Give or accept a gift or hospitality during commercial negotiations or a tender process if this could be perceived as intended or likely to influence the outcome.
• Accept a payment, gift or hospitality from a third party where you know or suspect it is offered with the expectation that KRCS will provide a business advantage in return.
• Accept hospitality from a third party that is unduly lavish or extravagant in the circumstances.
• Offer or accept a gift to or from government officials, representatives, politicians or political parties without prior approval from your manager or the Managing Director.
• Threaten or retaliate against anyone who has refused to commit a bribery offence or who has raised concerns under this policy.
• Engage in any other activity that might lead to a breach of this policy.

KRCS does not make, and will not accept, facilitation payments or kickbacks of any kind.

Facilitation payments are typically small, unofficial payments made to secure or expedite a routine or necessary action. Kickbacks are payments made in return for a business favour or advantage.

You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by KRCS or on its behalf. If asked to make a payment, you should consider what the payment is for, whether the amount is proportionate to the goods or services provided, and obtain a receipt that details the reason for the payment. Any concerns should be raised with your manager.

Reasonable and appropriate hospitality or entertainment may be given to or received from third parties for the purposes of establishing or maintaining good business relationships, improving or maintaining KRCS image or reputation, or marketing and presenting KRCS products and services effectively.

Gifts or hospitality must:

• Not be made with the intention of influencing a third party to obtain or retain business or a business advantage.
• Be given in KRCS name and not in an individual employee name.
• Not include cash or cash equivalents such as gift certificates or vouchers.
• Be appropriate in the circumstances, taking account of the reason, timing and value.
• Be given openly and not secretly.
• Comply with applicable local law.

Promotional gifts of low value, such as branded stationery to or from existing customers, suppliers and business partners, will usually be acceptable.

Reimbursing genuine and reasonable business expenses would not usually amount to bribery.

Payments in excess of genuine and reasonable business expenses are not acceptable.

The test to apply is whether the gift, hospitality or payment is reasonable and justifiable in all the circumstances. The intention behind it should always be considered.

KRCS does not make political contributions.

KRCS only makes charitable donations that are legal and ethical under local laws and practices. No donation may be offered or made without prior approval from the Managing Director.

KRCS must keep financial records and maintain appropriate internal controls to evidence the business reason for making payments to third parties.

All hospitality or gifts given or received must be declared and recorded in writing and will be subject to managerial review.

Expenses claims relating to hospitality, gifts or payments to third parties must be submitted in accordance with the expenses policy and must record the reason for expenditure.

All accounts, invoices and other records relating to dealings with third parties, including suppliers and customers, must be accurate and complete. Accounts must not be kept off-book to facilitate or conceal improper payments.

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for KRCS or under KRCS control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers something to gain a business advantage with KRCS, or indicates that a gift or payment is required to secure their business.

You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.

If you are offered a bribe, are asked to make one, or believe or suspect that bribery, corruption or another breach of this policy has occurred or may occur, you must report it in accordance with the Whistleblowing Policy as soon as possible.

If you are unsure whether a particular act constitutes bribery or corruption, raise it with your line manager.

KRCS aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

KRCS is committed to ensuring that no one suffers detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future.

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe you have suffered such treatment, you should inform your manager. If the matter is not remedied, employees should raise it formally using the Grievance Procedure in the Staff Handbook.

Training on this policy forms part of the induction process for all individuals who work for KRCS, and further training will be provided as necessary. The effectiveness of this policy and associated controls will be reviewed annually by senior management.

KRCS zero-tolerance approach to bribery and corruption must be communicated to suppliers, contractors and business partners at the outset of the business relationship and as appropriate thereafter.

1. Monitoring and Review

KRCS is committed to maintaining effective anti-bribery and anti-corruption controls and ensuring continued compliance with applicable legislation, regulatory requirements and industry best practice.

This policy will be reviewed at least annually by management as part of the KRCS Management Review process and may be reviewed sooner where:

• Changes in legislation or regulatory requirements occur.
• New business activities, products or services are introduced.
• Material bribery or corruption risks are identified.
• Internal audits, investigations or compliance reviews indicate that updates may be required.

The outcome of each review will be documented within the document control record and any required amendments will be approved by the Board or a designated member of senior management.

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

KRCS may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.

The following are examples of possible red flags that may arise during work for KRCS and may raise concerns under anti-bribery and anti-corruption laws. The list is not exhaustive and is for illustrative purposes only. If you encounter any of these red flags, you must report them promptly to your line manager.

• A third party engages in, or has been accused of engaging in, improper business practices.
• A third party has a reputation for paying bribes, requiring bribes to be paid, or having a special relationship with foreign government officials.
• A third party insists on receiving a commission or fee payment before committing to a contract with KRCS.
• A third party requests payment in cash, refuses to sign a formal agreement, or refuses to provide an invoice or receipt.
• A third party requests that payment is made to a country or location different from where the third party resides or conducts business.
• A third party requests an unexpected additional fee or commission to facilitate a service.
• A third party demands lavish entertainment or gifts before commencing or continuing negotiations or services.
• A third party requests that a payment is made to overlook potential legal violations.
• A third party requests that employment or another advantage is provided to a friend or relative.
• An invoice appears to be non-standard or customised.
• A third party insists on side letters or refuses to put agreed terms in writing.
• A commission or fee appears unusually large given the service provided.
• A third party requests or requires the use of an unknown agent, intermediary, consultant, distributor or supplier.
• You are offered an unusually generous gift or lavish hospitality by a third party.