Anti-Bribery & Anti-Corruption Policy

Skills4Stem Ltd is committed to conducting business in an ethical and
honest manner, and is committed to implementing and enforcing systems that ensure
bribery is prevented. Skills4Stem Ltd has zero-tolerance for bribery and
corrupt activities. We are committed to acting professionally, fairly, and with integrity in all
business dealings and relationships, wherever in the country we operate.

Skills4Stem Ltd will constantly uphold all laws relating to anti-bribery and
corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK,
including the Bribery Act 2010, in regards to our conduct both at home and abroad.

Skills4Stem Ltd recognises that bribery and corruption are punishable by imprisonment and a fine.
If our company is discovered to have taken part
in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering
for public contracts, and face serious damage to our reputation. It is with this in mind
that we commit to preventing bribery and corruption in our business, and take our legal
responsibilities seriously.

This anti-bribery policy applies to all employees (whether temporary, fixed-term, or
permanent), consultants, contractors, trainees, seconded staff, home workers, casual
workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons
associated with us (including third parties), or any of our subsidiaries or their employees,
no matter where they are located (within or outside of the UK). The policy also applies to
Officers, Trustees, Board, and/or Committee members at any level.

In the context of this policy, third-party refers to any individual or organisation our
company meets and works with. It refers to actual and potential clients, customers,
suppliers, distributors, business contacts, agents, advisers, and government and public
bodies – this includes their advisors, representatives and officials, politicians, and public
parties.

Any arrangements our company makes with a third party is subject to clear contractual
terms, including specific provisions that require the third party to comply with minimum
standards and procedures relating to anti-bribery and corruption.

Gifts and hospitality

Skills4Stem Ltd accepts normal and appropriate gestures of hospitality and
goodwill (whether given to/received from third parties) so long as the giving or receiving of
gifts meets the following requirements:

It is not made with the intention of influencing the party to whom it is being
given, to obtain or reward the retention of a business or a business advantage,
or as an explicit or implicit exchange for favours or benefits.

  • It is not made with the suggestion that a return favour is expected.
  • It is in compliance with local law.
  • It is given in the name of the company, not in an individual’s name.
  • It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
  • It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
  • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
  • It is given/received openly, not secretly.
  • It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
  • It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).
  • It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual
of a certain religion/culture who may take offence), the gift may be accepted so long as it is
declared to the compliance manager, who will assess the circumstances.

Skills4Stem Ltd recognises that the practice of giving and receiving
business gifts varies between countries, regions, cultures, and religions, so definitions of
what is acceptable and not acceptable will inevitably differ for each.

As good practice, gifts given and received should always be disclosed to the compliance
manager. Gifts from suppliers should always be disclosed.

The intention behind a gift being given/received should always be considered. If there is
any uncertainty, the advice of the compliance manager should be sought.

Kickbacks and Facilitation Payments

Skills4Stem Ltd does not accept and will not make any form of facilitation
payments of any nature. We recognise that facilitation payments are a form of bribery
that involves expediting or facilitating the performance of a public official for a routine
governmental action. We recognise that they tend to be made by low level officials with the
intention of securing or speeding up the performance of a certain duty or action.

Skills4Stem Ltd does not allow kickbacks to be made or accepted. We
recognise that kickbacks are typically made in exchange for a business favour or advantage.

Skills4Stem Ltd recognises that, despite our strict policy on facilitation
payments and kickbacks, employees may face a situation where avoiding a facilitation
payment or kickback may put their/their family’s personal security at risk. Under these
circumstances, the following steps must be taken:
Keep any amount to the minimum.
Ask for a receipt, detailing the amount and reason for the payment.
Create a record concerning the payment.
Report this incident to your line manager.

Political Contributions

Skills4Stem Ltd will not make donations, whether in cash, kind, or by any
other means, to support any political parties or candidates. We recognise this may be
perceived as an attempt to gain an improper business advantage.

Charitable Contributions

Skills4Stem Ltd accepts (and indeed encourages) the act of donating to
charities – whether through services, knowledge, time, or direct financial contributions (cash
or otherwise) – and agrees to disclose all charitable contributions it makes.

Employees must be careful to ensure that charitable contributions are not used to
facilitate and conceal acts of bribery.

We will ensure that all charitable donations made are legal and ethical under local
laws and practices, and that donations are not offered/made without the approval of the
compliance manager.

All employees and those under our control are equally responsible for the prevention,
detection, and reporting of bribery and other forms of corruption. They are required to avoid
any activities that could lead to, or imply, a breach of this anti-bribery policy.

If you have reason to believe or suspect that an instance of bribery or corruption has
occurred or will occur in the future that breaches this policy, you must notify the compliance
manager.

If any employee breaches this policy, they will face disciplinary action and could face
dismissal for gross misconduct. [COMPANY NAME] has the right to terminate a
contractual relationship with an employee if they breach this anti-bribery policy.

Internal control systems and procedures designed to prevent bribery and corruption are
subject to regular audits to ensure that they are effective in practice.

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