ANTI-BRIBERY Policy Statement

ANTI-BRIBERY POLICY

Policy Statement

Bribery is the practise of offering or receiving an incentive, to gain a reward or as an

advantage. A bribe can take on a variety of forms and can include cash, gifts, hospitality,

a contract award, or gaining inside information about up and coming work. Bribes are

given to a person with the intention of influencing the person to act in a way that favours

an individual or company.

Smile Network Group Ltd has a zero tolerance for bribery and corrupt activities. As an

organisation, we are committed to acting professionally, fairly and with integrity in all our

business dealings and relationships, and do not tolerate any form of bribery in its business.

Under the UK Bribery Act 2010, it is illegal to:

• Offer a bribe

• Agree to offer a bribe

• Accept a bribe

• Agree to accept a bribe

• Request a bribe

• Bribe a foreign public official

• Fails to prevent bribery in a commercial organization

Policy Responsibility

Smile Network Group Ltd, Finance Director has overall accountability for managing the risk of

bribery, ensuring this policy complies with our legal obligations, and that all those under

our control comply with it.

Employees of Home Smile Network Group Ltd should not offer, make, ask for, accept a payment, gift

or favour in return for favourable treatment, or to gain business advantage.

Scope

This policy applies to all employees that work or on behalf of Smile Network Group Ltd.

This includes, but is not limited to:

• Employees

• Contractors

• Consultants

• Suppliers

• 3rd parties

Anyone working on our behalf, or in our name, through outsourcing of services, processes

or any business activity, will be required to act consistently with this policy when acting on

our behalf.

Bribery Breaches

Bribery is a criminal offence under the UK Bribery Action 2010. Smile Network Group Ltd will

investigate any actual or suspected breach of this policy.

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. A breach of this legislation is likely

to result in criminal proceedings and possible imprisonment for the perpetrator.

Facilitating payments and kickbacks

Smile Network Group Ltd will not accept, facilitation payments or kickbacks of any kind.

Facilitation payments are typically small, unofficial payments offered to secure or expedite

an action. All employees must avoid any activity that might lead to a facilitation payment

or kickback.

Gifts, hospitality and expenses

Smile Network Group Ltd accepts normal and appropriate gestures of hospitality and goodwill, so

long as the giving or receiving of gifts meets the following requirements:

• It is not made with the intention of influencing the party to whom it is being given.
• It is not made with the suggestion that a return favour is expected.
• It is compliant with local law.
• It is given in the name of the company, not in an individual’s name.
• It is appropriate for the circumstances (small gift at Christmas).
• It is given or received openly and not secretly.
• It is not selectively given to a key, influential person, clearly with the intention of directly
• influencing them.
• It is not above a certain excessive value, as predetermined by the company’s compliance
• office.
• It is not offered to or acceptance from a government official or representative or politician or political party without prior approval of the company’s Compliance Officer.

Where it is inappropriate to decline the offer of a gift, the gift may be accepted if it is

declared to the Compliance office who will assess the circumstances.

As good practice, gifts given and received should always be disclosed to the Compliance

Officer. Gifts from suppliers should always be disclosed.

The intention behind a gift being given or received should always be considered. Any

uncertainty, then the advice of the compliance office should be sought.

Donations

We do not usually make contributions to any political parties.

We only make charitable donations that are legal and ethical under local laws and

practices.

Reporting a bribe

The prevention, detection and reporting of bribery is everyone’s responsibility.

If an employee has been offered a bribe or received an inappropriate request from someone we

do business with:

1. Do not accept the bribe and decline the request.

2. Inform your line manage that you think you may have been offered a bribe.

3. Report the incident to the Compliance Officer.