Anti Bribery Policy

It is WPL (UK) Limited’s policy to carry out business fairly, honestly and openly both at home and abroad. As such we have a zero tolerance approach towards bribery in any part of our operation. Bribery is defined as a promise offer or gift (financial or otherwise) to bring about the improper performance of a function or activity. Examples of this would be such as offering a potential client a gift such as a weekend away on the condition they do business with us. To meet this commitment the Company has the following systems in place to counter bribery:

Risk assessments will be documented to assess the levels of risk the Company is exposed to in its business, particularly its sales operations.

A clear entertainment and expenses policy that sets out that only reasonable entertaining and gift giving expenses will be accommodated by the Company and should not induce either party to contract.

All new employees will receive, as part of their induction, training on preventing, detecting and reporting bribery.

A whistle-blowing policy is also in place. If you are concerned that bribery has occurred, may occur or is likely to occur we would encourage you to report your concerns.

If you suspect or if you are asked to accept or offer a bribe you must report this immediately to the Managing Director, Richard Rowson. The Company values a proactive anti-bribery stance by any employee.

As we take our obligations to prevent bribery being committed very seriously, any breach of our anti-bribery policy or procedures will be considered to be gross misconduct and may result in your dismissal. Where you have been involved in or suspected of involvement in bribery that is not connected with this Company, this may still affect your suitability for on-going employment with us.

Whistleblowing Policy
Introduction
All organisations face the risk of things going wrong or of unknowingly harbouring malpractice. The Company believes it has a duty to identify such situations and take the appropriate measures to remedy them. By encouraging a culture of openness within our organisation the Company believes it can help prevent malpractice. Furthermore, by knowing about malpractice at an early stage the Company stands a good chance of taking the necessary steps to safeguard the interests of all staff and protect the organisation. In short, the Company encourages you to ‘blow the whistle’ on suspected malpractice.

Please be aware that this policy is not the procedure for general grievances. If any employee has a complaint about their own personal circumstances then they would use the normal grievance procedure. However for anyone with concerns about malpractice within the Company the procedure is outlined in this policy.

Suspected malpractice
The Company encourages you to report suspected malpractice in relation to our activities. We construe malpractice widely and this includes:

• Any illegal activity at the Company;
• Any activity that causes the Company to breach its legal obligations;
• Any activity that causes the Company to endanger the health and safety of any person;
• Any activity that damages the environment;
• Any attempt to wilfully conceal any information that tends to show malpractice.

You are not required to obtain evidence of malpractice before raising your concern. As such you must not commit an act or acts of misconduct, breach company rules or damage the Company in any way in order to obtain information. The Company is committed to ensuring that you work in an environment in which you can raise concerns and there is no question of you having to prove anything. The Company will support employees, who with the reasonable belief that it is in the public interest to do so raise concerns under this policy, even if they turn out to be mistaken.

How to raise your concern internally
If you feel able to do so you should tell the Managing Director, Richard Rowson, about your concern. There is no special procedure for doing this – you can tell Richard Rowson about the problem, or put it in writing if you prefer.

How the Company will respond
After you have raised your concern the Company will decide how to respond in a responsible and appropriate manner under this policy. Usually, this will involve making internal enquiries first, but it may be necessary to carry out an investigation at a later stage, which may be formal or informal depending on the nature of the concern raised.

As far as possible, the Company will keep you informed of the decisions taken and the outcome of any enquiries and investigations carried out. However, the Company will not be able to inform you of any matters that would infringe the duty of confidentiality owed to others.

If you ask for a matter to be treated in confidence the Company will respect your request and only make disclosures with your consent.

Raising your concern externally (exceptional cases)
The main purpose of this policy is to give you the opportunity and protection you need to raise your concerns internally. The Company would expect that in almost all cases raising concerns internally would be the most appropriate action for you to take.

However, if you feel you cannot raise your concerns internally and you honestly and reasonably believe the information and any allegations are true, you should consider raising the matter with the appropriate regulator.

If you have good reasons for not using the internal or regulatory disclosure procedures described above, you may consider making wider disclosure by reporting the matter to the police or to the media, for example. However, whistleblowers who make wider disclosures of this type will only be protected in certain circumstances. The Company recommends that you take legal advice before following this course of action since we believe it will be in your own interests to do so.

Protection for whistleblowers
You may be worried that by reporting your concerns you will be opening yourself up to victimisation or detriment, or risking your job security. However, all staff benefit from statutory protection if they raise concerns in the right way and do so with the reasonable belief that raising the concern is in the public interest. This protection means that employees must not be dismissed or suffer any detrimental treatment as a result of raising a concern. As it will be in your own interests to do so we would encourage you in particular to ensure you have a reasonable belief that the disclosure you wish to make is in the public interest as this is one of the requirements that must be met in order to obtain the statutory protection mentioned earlier.

Staff must not threaten or retaliate against whistleblowers in any way. This will be regarded as gross misconduct and may result in those involved being dismissed without notice or payment in lieu of notice.

If you believe that you have suffered any detrimental treatment, you should inform your manager immediately. If the matter is not remedied you should raise it formally in writing to the Managing Director, Richard Rowson.