ANTI-CORRUPTION AND BRIBERY POLICY

Date of Policy: 1 November 2020 

1. About this policy 

1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally, fairly  and with integrity in all our business dealings and relationships.  

1.2 The purpose of this policy is to: 

(a) set out our responsibilities, and of those working for us (whether as employees,  consultants or agents), in observing and upholding our position on bribery and  corruption; and 

(b) provide information and guidance to those working for us on how to recognise and  deal with bribery and corruption issues. 

(c) This policy should be read in conjunction with the Whistle blowing policy, receipt of  resident gifts policy and relevant clause in site specific employment contracts. 

1.3 Any employee who breaches this policy will face disciplinary action, which could result in  dismissal for gross misconduct. Any non-employee who breaches this policy may have their  contract terminated with immediate effect. 

1.4 This policy does not form part of any employee's contract of employment and we may amend it  at any time. It will be reviewed regularly. 

1.5 Where we outsource any of our activities to third parties (such that they are or may be  associated persons within the meaning of Bribery Act 2010, the “Act”), our policy is to: 

(a) require them to comply with their legal responsibilities to no less a standard than is  required by this policy; and  

(b) monitor their compliance with relevant policies and procedures to ensure that they are  adequately enforced.  

2. Who must comply with this policy? 

2.1 This policy applies to all persons working for us or on our behalf in any capacity, including  employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, business partners and any other associated persons. 

3. What is bribery? 

3.1 Bribe means a financial or other inducement or reward for action which is illegal, unethical, a  breach of trust or improper in any way. For example, Bribes can take the form of money, gifts,  loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or  benefit. 

3.2 Bribery includes offering, promising, giving, accepting or seeking a bribe. 

3.3 All forms of Bribery are strictly prohibited. If you are unsure about whether a particular act  constitutes Bribery, raise it with your manager, the Allegra Services Operations Support  Manager or the Allegra Services Chairman. 

3.4 Specifically, it is not acceptable for you (or someone on your behalf) to: 

(a) give or offer any payment, gift, hospitality or other benefit in the expectation that a  business advantage will be received in return, or to reward any business received; 

(b) accept any offer from a third party that you know or suspect is made with the  expectation that we will provide a business advantage for them or anyone else; 

(c) give or offer any payment (sometimes called a facilitation payment) to a government  official in any country to facilitate or speed up a routine or necessary procedure; 

(d) give or accept a gift, hospitality or other benefit during any commercial negotiation or  tender process (including, but not limited to, those involving third party suppliers or  acquisitions of land), if this could be perceived as intended or likely to influence the  outcome; or] 

(e) engage in any other activity that might lead to a breach of this policy. 

3.5 You must not threaten or retaliate against another person who has refused to offer or accept a  Bribe or who has raised concerns about possible Bribery or corruption. 

4. Gifts and hospitality 

4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or  marketing our products and services.  

4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen  as an inducement or reward for any preferential treatment (for example, during contractual  negotiations or a tender process).

4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking  account of the reason for the gift. Gifts must not include cash or cash equivalent (such as  vouchers), or be given in secret. Gifts must be given in our name, not your name. 

4.4 Promotional gifts of low value such as branded stationery may be given to or accepted from  existing customers, suppliers and business partners 

4.5 Nothing in the above statements overrides the restrictions on staff accepting gifts from  residents, families and others in accordance with the site specific policy and employment  contract clauses.  

5. Record-keeping 

5.1 Site based personnel must declare gifts in accordance with the site policy to the registered  manager. Central team personnel must declare by lodging with the CFO a written record of all  hospitality or gifts given or received. You must also submit all expenses claims relating to  hospitality, gifts or payments to third parties in accordance with our expenses policy and record  the reason for expenditure.  

5.2 All accounts, invoices, and other records relating to dealings with third parties including  suppliers and customers should be prepared with strict accuracy and completeness. Accounts  must not be kept "off-book" to facilitate or conceal improper payments. 

6. How to raise a concern 

6.1 If you are offered a Bribe, or are asked to make one, or if you suspect that any bribery,  corruption or other breach of this policy has occurred or may occur, you must notify your  manager, the Operations Support Manager or the Allegra Services Chairman as soon as possible.