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Bribery and Corruption Policy

1. Introduction:

The purpose of this document is to set out the firm’s policy in relation to bribery and corruption. The policy applies strictly to all employees, directors, agents, consultants, contractors, joint ventures, partnerships, and to any other people or bodies associated with both Leafield Environmental Ltd and Leafield Environmental Holdings Ltd, within all company activities, regions, areas and functions.

2. Objective:

The Company is committed to maintaining the highest standards of ethics and integrity in the conduct of its business throughout the world.

Bribery and corruption no matter how minor is illegal in all the countries in which the Company operates. Those who break the law of the land are liable to be prosecuted. In addition, alleged offenders who are UK citizens can be prosecuted in the UK no matter where the offence was committed pursuant to the Bribery Act 2010.

3. Definitions:

“Bribery” means the making of a Payment which is prohibited by this policy, and “Bribe” means a Payment which is so prohibited.

“Corruption” means the unlawful conferring or obtaining of an advantage or benefit (whether commercial or personal) or otherwise inducing a person to act dishonestly or unfaithfully, whether by the making of a Payment or otherwise.

“Donee” or “Donor” shall include (a) any individual, (b) any family, friend, associate or acquaintance of that individual, and (c) any company or other entity established by or for the benefit of any of them.

“Payment” means a payment, gift or other benefit of any nature, whether direct or indirect.

“The Company” means Leafield Environmental Ltd or any company, joint venture or partnership to which Section 1 above refers.

4. Policy:

Bribery and Corruption in all forms is prohibited.

No person to whom this policy applies may commit, or knowingly assist another person to commit, a breach of this policy.

A breach of this policy will be regarded as gross misconduct and result in action being taken under the company’s disciplinary rules and procedures.

5. What is prohibited:

Making a Payment to secure a vote for, or to encourage or procure, an approval, consent or permit in respect of which the Donee has an administrative or other legal responsibility or role or which he or she is otherwise able to influence.

Making a Payment to an agent, customer, contractor, supplier or other third party (or an employee of any of them) to encourage or induce from the Donee (a) a contract or other commitment, or one on terms more favourable than those otherwise on offer, or (b) the procurement or securing of any other act of Corruption.

Making a Payment to someone operating an administrative process to facilitate or accelerate the implementation of that process.

Making a political or charitable donation, or granting any sponsorship, the underlying purpose for which is Corruption.

Any other act of Corruption.

Agreeing or offering to do anything prohibited by any of the above.

Doing anything of a similar nature to any of the above which is illegal under the laws of the country in which the relevant act or proposal is, or is to be, undertaken or made.

Authorising or knowingly assisting any third party engaged to represent the Company to do any of the above.

Accepting a Payment to encourage or induce the Donor or a party connected with the Donor (a) to accept a contract or other commitment from the Company, or one on more favourable terms than those otherwise on offer, or (b) to commit any other act of Corruption.

Entering, directly or indirectly, into a contract or other commitment for personal gain or benefit with anyone in any way relating to a transaction or other arrangement entered into, or being negotiated by the Company.

6. What is permitted:

Corporate hospitality within the limits established by the Company Gift and Entertainment Policy.

The use of a legitimate fast-track process which is available to all on payment of a fee.

The offer of resources to assist a person or body to make a decision more efficiently provided they are supplied for that purpose only.

7. Agents and consultants:

The terms of engagement of any agents or consultants must be in writing, and in line with the requirements of the Company Contracts Policy.

It must include terms having the following effect:

> The agent or consultant must comply with this Policy and carry out its duties lawfully and properly.

> The agent or consultant must carry out the prescribed services in its own name.

No power of attorney is, or will be, granted to the agent or consultant authorising it to act in the name of the Company except on written request identifying a specific purpose and then at the Boards sole discretion. If a power of attorney is to be granted having a wider scope, this must be approved in advance by the Board and its nominated Legal representatives of the Company.

The contract sum must (a) fairly reflect the nature and extent of the duties to be undertaken and be consistent with the normal market rate for those services and (b) be inclusive of all expenses incurred. Where necessary, the contract may provide for reimbursement of expenses of a nature specifically identified in the contract provided that the expenses are lawfully incurred.

Any variation or waiver will not be effective unless signed by both parties.

8. Reporting and Investigation:

The prevention, detection and reporting of Bribery and Corruption is the responsibility of all employees.

Suspicions and allegations must be reported to Company Compliance Manager or HR. They will ensure an independent investigation and can also provide guidance.