Anti-Bribery & Anti-Corruption Policy

Easy Supply LTD (trading as Easy Supply, company number 16202697) is committed to conducting business fairly, honestly and openly. This policy sets out our responsibilities, and those of everyone who works for or with us, in observing and upholding our position on bribery and corruption. It is grounded in the Bribery Act 2010.

This policy applies to all individuals working at all levels, including directors, employees, agency staff, contractors, agents, suppliers, consultants and any other person or entity associated with us, wherever located.

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 wherever we operate. We will uphold all laws relevant to countering bribery and corruption in the jurisdictions in which we operate, including the Bribery Act 2010.

Bribery is a criminal offence in the UK. It can result in unlimited fines for the company and up to 10 years' imprisonment for individuals, as well as serious reputational damage.

A bribe is a financial or other inducement or reward offered, promised, given, requested or accepted to influence a person to act improperly, or to reward them for doing so. The Bribery Act 2010 creates four principal offences:

• Bribing another person — offering, promising or giving a bribe (section 1).
• Being bribed — requesting, agreeing to receive or accepting a bribe (section 2).
• Bribing a foreign public official — to obtain or retain business or an advantage (section 6).
• Failure of a commercial organisation to prevent bribery carried out on its behalf (section 7) — the corporate offence, for which the only defence is having adequate procedures in place.

This policy does not prohibit normal and appropriate hospitality, or the giving and receiving of modest gifts, provided they are reasonable and proportionate. Any gift or hospitality is only acceptable if it:

• Is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or advantage.
• Is given in our name, openly and transparently, not to or from anonymous parties.
• Is of an appropriate type and value and given at an appropriate time.
• Complies with local law and does not include cash or a cash equivalent.

If you are ever in doubt as to whether a gift or hospitality is appropriate, you must seek approval before accepting or offering it.

We do not make, and will not accept, facilitation payments (small unofficial payments made to secure or expedite a routine government action) or kickbacks of any kind. Facilitation payments are illegal under the Bribery Act 2010. If you are asked to make such a payment on our behalf, you must refuse and report the request immediately.

We do not make contributions to political parties. We may support charitable causes and make reasonable charitable donations, but only where they are legal and ethical under local laws and practices, and are never made as a means of improperly obtaining or retaining a business advantage. All donations must be approved in advance and properly recorded.

We keep accurate and up-to-date financial records and have appropriate internal controls in place that will evidence the business reason for making payments to third parties. All expenses claims relating to hospitality, gifts or expenses incurred to third parties must be submitted in accordance with our expenses policy and specifically record the reason for the expenditure. All accounts, invoices and other documents relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts may be kept "off the record".

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You must avoid any activity that might lead to, or suggest, a breach of this policy. You must notify us as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

We encourage everyone to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage. If you are offered a bribe, are asked to make one, suspect that any bribery or corruption may occur in the future, or has occurred, you must report it as soon as possible to [email protected] or by telephone on +44 7956 786011.

We are committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith a suspicion that an actual or potential bribery or other corruption offence has taken place or may take place.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We may terminate our relationship with any other individual or organisation working on our behalf if they breach this policy. Both individuals and the company may also face serious criminal and civil penalties under the Bribery Act 2010.

The directors of Easy Supply LTD are responsible for monitoring the effectiveness of this policy and will review its implementation regularly, considering its suitability, adequacy and effectiveness. This policy will be reviewed at least annually and updated as required. Our registered and trading addresses are: Registered Office: Flat 200 Edinburgh House, Edinburgh Gate, Harlow, CM20 2TJ, United Kingdom — Trading/Warehouse: Unit 6 Marshall Paving, Cattlegate Road, Enfield, EN2 9ED, United Kingdom. For questions about this policy, contact [email protected].