Anti Corruption Policy

THE BRIBERY ACT 2010 (Implementation 1 July 2011)

The Bribery Act 2010 requires commercial organisations to assess whether they have adequate processes in place to ensure that they are not involved in bribery and corruption. The following Policy sets out the Firm’s proposals for prevention of corruption and the monitoring, identification and management of issues that arise as a result of any corruption that may be discovered in an attempt to avoid or mitigate any potential liability as a consequence.

This Policy applies to all employees, agents, business partners or consultants with whom the firm works and is effected by way of initial induction & staff training around general business awareness of the risks that exist within the accountancy sector.

The Directors are responsible for the implementation and enforcement of the anti corruption policy. The Directors take a stance that the culture of the Firm is such that bribery is never acceptable and this Policy is designed to confirm that statement and relevant processes that explicitly apply.

The Directors will ensure compliance with the Policy by :

• Reviewing the risks that face the organisation
• Developing and reviewing an Anti Corruption Code of Conduct which covers gifts, hospitality and facilitation payments
• Devising, updating and providing training to all relevant employees
• Carrying out due diligence in relation to third parties
• Reviewing this Anti Corruption Policy on a regular basis
• Monitoring a Gift & Hospitality Register set up to assist procedures
• Reporting to statutory authorities knowledge of Bribery or Corruption arising in connection with the operation of our business

Risk Assessment

In order to achieve a corruption-free regime everyone must understand and regularly assess the risk of corruption that is faced within our business and that of those who may provide services on our behalf..

This Policy Statement has been produced on the basis of the current risk that exists and the measures that have been put in place relating directly to our considered view of the risks.

The matters that have been taken into account in considering the risk to the business are jurisdictional. We do not conduct business in areas that we consider to be higher risk countries and the majority of work carried out by the firm is conducted within the UK; with a very minor level of work in some European and other overseas countries. All these jurisdictions are considered to be of relatively low risk.

The Firm does not provide services to clients in sectors which are considered to be high risk – those include the defence and natural resources sector and areas of major public works. The one sector that the business does work with that may be considered high risk is the construction sector. However, the involvement in relation to this sector is minimal and primarily in relation to computation of taxation liabilities where it is considered that the possibility of corruption is far more limited than in general every-day construction process.

The Firm does not deal with public officials and therefore does not consider that it is at risk under Section 6 of the Act.

The organisation does not currently work on Government sponsored projects except under audit requirements of clients who may have received funding. However this will be continually monitored and in the event that this position changes, the Policy will be updated.

The organisation does not use intermediaries or enter into joint venture Agreements and therefore the risk of controlling the activities of third parties within the business is not of particular significance at the current time. From time to time we may as part of our service to clients refer them to other organisations. In such cases the values of those referred organisations will be aligned with our own.

Walker Thompson’s Anti Corruption Code of Conduct

Our Code of Conduct expressly prohibits all forms of corruption; both from a moral and practical standpoint. Gifts such as cash, gifts, donations and hospitality such as meals, hotels, invitations to arts and sporting events may be considered as bribes and therefore it is a requirement of the organisation that all and any such “gifts or hospitality” must be reported to a Director or if receipt is by a Director to a second Director. The Firm’s Policy in relation to such “gifts” is that these should always be turned down immediately that they are offered; making reference to the Firm’s Policy in relation to anti corruption unless they are of a nominal value (currently considered to be no greater than £100). If such gifts are unable to be rejected at source, they must be reported to a Director in line with the above, who will then make a decision on action to be taken.

As far as the giving of “gifts” or “hospitality” is concerned, the organisation’s Policy is that gifts should only ever be given with the approval of a Director and that any gifts should be a “token” only with guidance being that they should not exceed the value of £100.

The organisation has a zero tolerance of bribery and corruption. This Policy extends to all of the firm’s business dealings and transactions. All Directors and employees are required to comply with this Policy.

All parts of the firm will adhere to the Policy for countering bribery & corruption. This will include practises including recruitment, induction, promotion, training, performance evaluation, remuneration and recognition – all of which reflect the organisation’s commitment to the Policy.

No employee will be prejudiced in any way for refusing to pay bribes even if such refusal may result in the organisation losing business.

Compliance with the Firm’s training programme is mandatory for all employees and Directors and failure to attend or adhere to the training given in respect of the Anti Corruption Policy will be considered as a disciplinary offence.

It is acknowledged that one of the highest risk areas for bribery for an organisation such as ours lies in proposals for reducing tax liabilities where employees are most vulnerable to being in receipt of influence. It is acknowledged that a further pressure for employees is that Walker Thompson’s competitors may be prepared to pay bribes to secure competitive advantages. We would emphasise that this Policy in no way condones any form of payment or bribe and further strictly prohibits it.

Where sections of the business have greater exposure to the risks, particular attention will be given to those areas in training and monitoring.

Training

The training needs of the organisation in respect of Anti Corruption will be continually monitored and will be provided as and when considered appropriate to all members of Directors &Staff. Training will include time for the Policy to be read and all Staff will confirm in writing that they have read and understood this Policy.

General training will be given upon implementation of this Policy and thereafter as and when it is considered to be required. All new employees will be required to sign to confirm that they have read and understood the terms of the Policy as part of their induction process.

Gifts & Hospitality Register

The Firm will maintain a Register of all gifts and hospitality that are reported as having been received or offered. Staff should report the receipt or offer of a gift to a Director immediately it is suggested, irrespective of whether it is subsequently accepted.

Audit Process

The Policy, Gifts & Hospitality Register and the workings of the organisation will be reviewed at least every 12 months and earlier if there are issues brought to the attention of the Directors that require addressing.

This Policy is implemented on the basis of its incorporation within the Staff Handbook and should be read in conjunction with that manual.

The Policy is, wherever appropriate, to be read in conjunction with the office Money Laundering Policy and other policies which may impact upon the financial integrity of the business.

Last Updated 13 April 2011