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Anti-Bribery & Anti-Corruption Policy

Last updated: 7th September 2022

At Arriba, we have a zero-tolerance policy on bribery and corruption. This policy outlines the expectations and responsibilities of all employees in upholding this standard.

It also serves as a resource for Arriba employees to identify and confront bribery and corruption concerns, as well as to understand their responsibilities.

01. Policy Statement

At Arriba, we only engage in ethical and honest business practices. We have anti-bribery systems set in place to prevent any corrupt activities. Our code of conduct requires all employees to act professionally and with integrity at all times.

Arriba will always uphold the law regarding anti-bribery and corruption, specifically the Bribery Act 2010, both domestically and internationally.

At Arriba, we are well aware of the potential consequences of bribery and corruption – up to ten years in prison and a large fine. If our company is found to be corrupt, we may face an unlimited fine, lose the ability to compete for public contracts, and suffer irreparable damage to our reputation. We, therefore, take our legal responsibilities seriously and commit to preventing bribery and corruption in all aspects of our business.

02. Bribery Definition

Bribery is the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting anything of value or a benefit to induce or persuade someone to take action or make a decision.

A bribe refers to any inducement, reward, or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage.

Not only is it illegal to give a bribe, but it’s also against the law to accept one.

Bribery is illegal. Employees are not to engage in any form of bribery, whether directly, passively (as described above), or indirectly (through a third party, such as an agent or distributor). They must not bribe a foreign public official from anywhere in the world. They must not accept offers in any form and, if they are unsure about what is a gift or act of hospitality, should seek further counsel from the company’s compliance manager.

03. Policy Coverage

03.1. Who This Policy Applies To?

This anti-bribery policy applies to all members of staff at any level, as well as consultants, contractors, trainees, agency staff, volunteers, interns and agents both in the UK and abroad.

When we mention “third-party” in this policy, we’re talking about any individual or organisation our company encounters while working. This includes actual and potential clients, customers, business contacts, suppliers, distributors, agents, advisers and government bodies – as well as their advisors, representatives, officials, politicians and public parties.

We only make arrangements with third parties that have clear contractual terms and comply with our minimum requirements.

03.2. What is Acceptable and Isn’t Acceptable?

When considering what is acceptable and what isn’t acceptable, we give refer to four areas; gifts and hospitality, facilitation payments, political contributions and charitable contributions.

03.2.1. Gifts and Hospitality

Arriba accepts normal and correct 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:

  1. It is not made to influence 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.
  2. It is not made with the suggestion that a return favour is expected.
  3. It complies with local law.
  4. It is given in the name of the company, not in an individual’s name.
  5. 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).
  6. It is of decent quality and value, given at the proper time, as determined by the intent behind the present.
  7. It is given/received openly, not secretly.
  8. It is not selectively given to a key, influential person, clearly to directly influence them.
  9. It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.

When a gift is offered in inappropriate situations (for example, when meeting with someone of a specific religion/culture who may be insulted), the gift can be accepted if it is notified to the compliance manager, who will evaluate the circumstances.

Arriba understands that definitions of what is appropriate to give or accept as a business gift vary depending on the country, region, culture, and religious beliefs.

For the compliance manager, it is always good practice to disclose gifts given and received, especially if they are from suppliers.

Always consider the intention behind a gift being given/received. If there is any uncertainty, seek out the advice of the compliance manager.

03.2.2. Facilitation Payments and Kickbacks

Arriba 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 to secure or speed up the performance of a certain duty or action.

Arriba does not allow kickback payments for any reason. We understand that kickbacks are frequently given as thanks for a business favour or benefit.

Arriba acknowledges that it is our employees may find themselves in a compromising position where not giving into a facilitation payment or kickback could threaten their safety or the safety of their families. If an employee finds themselves in this situation, they must take the following steps:

  1. Keep any amount to a minimum.
  2. Ask for a receipt, detailing the amount and reason for the payment.
  3. Create a record concerning the payment.
  4. Report this incident to your manager.

03.2.3. Political Contributions

Arriba will not, in any manner, contribute to any political parties or candidates. We understand that this may be perceived as an attempt to gain a business advantage.

03.2.4. Charitable Contributions

Arriba allows and encouraged donating to charities. This can be done through services, knowledge, time or direct financial contributions (cash or otherwise). Furthermore, Arriba agrees to disclose all charitable donations it makes.

Employees must be vigilant to ensure that charitable donations are not utilised to facilitate or conceal acts of bribery.

We only donate to charities that are legal and ethical under local laws and practices, and have the approval of the compliance manager.

04. Employee Responsibilities

At Arriba, our employees must take the time to read and fully understand this policy. Furthermore, they must comply with any training or other anti-bribery and corruption information given to them.

Everyone employed and under our control must take equal responsibility in the prevention, detection, and reporting of bribery or any other types of corruption. They are required to steer clear of any activities that could result in, or give the appearance of violating this anti-bribery policy.

If you have reason to believe or suspect that a case of bribery or corruption has occurred, is occurring, or will occur in the future that violates this policy, you must report it to the compliance manager.

Any employee who fails to comply with this code of conduct will be penalized and may face termination for serious misconduct. If an employee breaches this anti-bribery policy, the Managing Director has the authority to terminate their employment contract.

05. Concerns

05.1. Raise a Concern

If you have concerns regarding Arriba and feel that there is bribery or corrupt conduct, you must bring them to the attention of your employer as soon as possible. If you’re not sure whether certain behaviour or act can be considered bribery or corruption, talk with the compliance manager.

Arriba will ensure that all employees are aware of the whistleblowing procedures so that they can voice their concerns promptly and in confidence.

05.2. Victim of Bribery or Corruption

You must immediately notify your compliance manager if you are given a bribe, asked to make one, believe you may be bribed or asked to make a bribe in the future, or have reason to think that you are a target of any other corruption.

05.3. Protection

Arriba understands that if you report a concern or potential act of bribery or corruption, you may feel worried about potential repercussions. If you raise concerns in good faith under this policy, Arriba will support you even if the investigation finds that they were mistaken.

At Arriba, we do not allow anyone to be treated unfairly because they have refused to engage in bribery or other illegal activities.

Treatment that is detrimental to an individual’s health, well-being, or livelihood may include any of the following: termination, disciplinary action, treatments (including medications), and unfavourable treatment in connection with the problem addressed.

You should inform your compliance manager as soon as possible if you think you’ve been wronged due to an issue or refusal to take a bribe.

06. Training and Communication

Arriba will provide training on this policy during the onboarding process for all new staff. Employees will be given regular, relevant education regarding how to obey this rule and will be required to formally accept it once a year.

Arriba has a zero-tolerance attitude towards bribery and corruption, which will be made clear to all suppliers, contractors, business partners, and any third parties at the start of business relationships, and as needed thereafter.

Arriba will provide anti-bribery and corruption education to staff, as well as where we believe their understanding of how to comply with the Bribery Act might be enhanced. All firms should give their employees anti-bribery training, as a recommended best practice, anytime there is a chance of encountering bribery or corruption while doing business.

07. Record Keeping

Arriba will maintain thorough and accurate accounting records, as well as effective internal controls in place to provide evidence for all payments made. We will record the amount and reason for hospitality or gifts received and offered, as well as the date that they were accepted and distributed, in writing.

08. Monitoring and Reviewing

The compliance manager at Arriba is in charge of monitoring the policy’s success and will conduct checks on its implementation regularly. They will evaluate its appropriateness, sufficiency, and efficiency.

We regularly audit our internal control systems and procedures to make sure they are working effectively to prevent bribery and corruption.

We continuously seek ways to improve this policy and encourage employees to provide feedback on how it may be further improved. If you have suggestions for improvement, please direct them to the compliance manager.

Arriba reserves the right to change this policy at any time to improve its effectiveness against bribery and corruption.