ZERO7 Group appreciate the importance of ethical behaviour in our relations with clients, stakeholders, contractors and our employees. We are committed to ethical behaviour and this policy is part of those commitments.

This policy sets out the responsibilities of ZERO7 Group and its businesses in preventing bribery and corruption.


Definition

For the purposes of this policy, bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favour, or a financial or other advantage from another to influence a business outcome improperly, or to induce or reward improper conduct.


Bribery and corruption can be direct or indirect through third parties such as agents, brokers and/or joint venture partners.

Scope

Under the UK Bribery Act 2010, ZERO7 Group is required to put procedures in place to prevent bribery by any individual and/or organisation that performs services for or on behalf of ZERO7 Group.

Consequently, this policy applies to every employee, contractor, director and officer of ZERO7 Group.

Contractors, consultants or suppliers who are our agents or who are working on our behalf or as part of ZERO7 Group in our name, through outsourcing of service(s), processes or any business activity, will be required to act consistently with this policy when acting on our behalf. Independent contractors, consultants and/or suppliers will be made aware of this policy.


Policy

ZERO7 Group does not tolerate any form of bribery and/or corruption.

Any offer to pay, make, seek or accept any personal payment, gift and/or favour in return for favourable treatment and/or to make a gain in any business advantage must not be made. You must follow the anti-bribery and corruption laws to which you and ZERO7 Group are subject to and at the time operational in accordance with U.K. law.

You are liable to disciplinary action, dismissal, legal proceedings and possibly imprisonment if you are involved in bribery and/or corruption.

Bribery and corruption is unacceptable.

You must comply with ZERO7 Group’s procedures for the prevention of bribery and corruption.


Adequate procedures

Anti-bribery and corruption are a business priority. ZERO7 Group shall regularly and systematically identify bribery and corruption risks in its business and implement adequate risk-based procedures aimed at preventing bribery and corruption occurring including:

Communication – We will communicate this policy and relevant guidance to employees across the Company, through our established internal communication channels. We will also communicate this policy to our suppliers, contractors and business partners and wider stakeholders.

Training – We will ensure that those within the scope of the policy receive training appropriate to their activities and the associated risks.

Records – We will maintain adequate records which properly and fairly document all financial transactions. We will maintain written evidence to record compliance with this policy.

Audit – Our internal control systems will be subject to regular internal and independent audit to provide assurance that they are effective in countering bribery and corruption.

Business relationships – We will ensure that our business partners –including contractors, suppliers and agents –are fit to do business with in accordance with this policy.

Supply chain – We will address bribery and corruption risk in our supply chain by ensuring that payments made for goods and services are reasonable.

Conflicts of interest – Gifts and hospitality – We will address conflicts of interest and the risks created by gifts and hospitality through the implementation of our internal policies.


Responsibilities

The Managing Director is the director with primary accountability for our anti-bribery and corruption efforts and shall report the results of adherence to this policy at least annually to the ZERO7 Group Board of Directors.

Each director has responsibility for implementing the anti-bribery and anti-corruption strategy, policy and process within their designated section of ZERO7 Group.


Reporting actual or potential violations and seeking guidance

You must report actual, potential or suspected corruption by any individual or organisation with whom ZERO7 Group does business. Failure to do so may result in liability for ZERO7 Group and for you personally.

You must report any request for an improper payment and report any indication that a person may be making corrupt payments or that a person has an intention or plan to violate this policy.

You have a similar obligation to report any information or knowledge of any hidden fund or asset, of any false or artificial entry in ZERO7 Group ’s books and records. Any payment that circumvents ZERO7 Group’s internal financial processes must be reported.

Reports must be made immediately upon knowledge. Your report may be made to the relevant director in your department or to the Managing Director.

When any instance of bribery and/or corruption is identified, an investigation will take place under the guidance of the Managing Director or their nominated person.

You can also contact your direct line manager to seek advice on anti- bribery and corruption issues or to make suggestions for how we could improve our anti-bribery and corruption policy and procedures.


Monitoring and review

ZERO7 Group and the board of directors are committed to regular review and will assess the company’s compliance with this policy.

ZERO7 Communications Ltd

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ZERO7 Group Board of Directors may also make an independent assessment of the adequacy of the policy in response to an event such as an instance of bribery.