Anti-Bribery and Corruption

The purpose of this policy is to set out the responsibilities of Invicta Building Services Limited in observing and upholding our position on bribery and corruption.

All Invicta Building Services Limited personnel are expected to conduct company business in a legal and ethical manner. Invicta Building Services Limited should not use illegal payments, bribes, kickbacks or other questionable inducements to influence government policy or any business transaction. The use of Invicta Building Services Limited funds or assets for any unlawful, improper or unethical purpose is prohibited. In the conduct of business, all employees must avoid making payments that may be or may be perceived to be improper. Specifically, Invicta Building Services Limited prohibits bribery by any of its employees or agents.

This policy applies to Invicta Building Services Limited employees (staff, contract and temporary). Where we have a minority interest we will encourage the application of this policy amongst our business partners including contractors, suppliers and joint venture partners.

The Managing Director is the main board director with primary responsibility for implementing this policy.

Invicta Building Services Limited values its reputation for ethical behaviour and for financial integrity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:

• Setting out a clear anti-bribery policy.
• Encouraging its employees to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately.
• Requiring all employees to act honestly and with integrity at all times and to safeguard the Company resources for which they are responsible.
• Ensuring transactions are properly and accurately recorded.
• Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution.
• Taking firm and vigorous action against any individual(s) involved in bribery.

Invicta Building Services Limited prohibits:

the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement

to or from

any person or company, wherever they are situated and whether they are a public official or body or private person or company

by

any individual employee, agent or other person or body acting on Invicta Building Services Limited’s behalf

in order to

gain any commercial, contractual or regulatory advantage for Invicta Building Services Limited a way which is unethical

or in order to

gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual

Invicta Building Services Limited recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of Invicta Building Services Limited or of the person or body employing them or whom they represent.

This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:

• normal and appropriate hospitality
• the giving of a ceremonial gift on a festival or at another special time

Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the Company Secretary or a Director before proceeding.

The prevention, detection and reporting of bribery is the responsibility of all employees within Invicta Building Services Limited. Suitable channels of communication by which employees or others can report in confidence any suspicion of bribery will be maintained the Company Secretary.
Training and communications

We will communicate this policy and relevant guidance to employees within Invicta Building Services Limited through our established internal communication channels. We will also communicate this policy to our suppliers, contractors and business partners and wider stakeholders.

Employees are encouraged to raise concerns about any instance of malpractice at the earliest possible stage through either their line manager, or the Company Secretary.

The Directors will review the implementation of this policy in respect of its suitability, adequacy and effectiveness and make improvements as appropriate.

The key legislation and/or sources of Global best practice that input into this policy are:

• UK Fraud Act 2006
• Bribery Act 2010
• UK Anti-Terrorism, Crime & Security Act 2001
• UK Corporate Governance Code (2010)
• UK Money Laundering Regulations 2007
• UN Convention Against Corruption (2003)
• Convention on Combating Bribery of Foreign Public Officials in International
• Business Transactions (OECD)
• Council of Europe Criminal Law Convention on Corruption (1998) and
• additional Protocol (2005)

Fraud: Intentional misrepresentation or concealment of the truth in order to secure something of value from another. The Fraud Act 2006 includes fraud by false representation, by failing to disclose information and by abuse of position.

Corruption: Illegal, immoral or dishonest behaviour.

Bribe: to ask or make someone do something for you, in return for payment (for example, but not limited to) payment, gifts, money or favours.

This policy has been endorsed by Nick Gallagher, Managing Director and has the full support of the company’s senior management team. It is reviewed at least annually and updated, if necessary, following consultation with the company’s employment law consultants.