1. INTRODUCTION

1.1 Background

Corruption and bribery are recognized as barriers to free trade and sustainable development.

Anti-corruption laws criminalize any such action paying, offering or giving anything of value to e.g. government officials, political candidates or business partners with the purpose of influencing the person’s decisions in order to obtain undue advantages. Consequences can be fines and/or imprisonment undermining the business causing huge financial, regulatory and reputational risks for the company. Laws like the UK Bribery Act reaching beyond the countries in question have changed the previous principle of laws being isolated to national legislation. As a matter of policy, ISF Group Limited wishes to comply with the laws and regulations in the countries in which it operates including international applicable anti-corruption laws (Commitment 10 of the ISF Group Limited Code of Conduct) and we expect our business partners to do the same.

1.2 Purpose

The purpose of this Corruption and Bribery Policy is to ensure compliance by all employees of ISF Group Limited with relevant laws of countries of which business is conducted or intended. The policy defines and describes ISF Group Limited’s position on:

• Corruption and bribery
• money laundering
• facilitation payment
• charitable contributions and sponsorships
• gifts, entertainment and favours

1.3 Scope

This Policy applies to all ISF Group Limited entities and business partners.

2. POLICY STATEMENT

2.1 Corruption and Bribery

Corruption and bribery are common terms for giving or obtaining an undue advantage through means which are illegal.

ISF Group Limited does not approve of any kind of corruption or bribery whether direct or indirect or through third parties (e.g. business partners, agents). Employees are prohibited from soliciting, arranging or accepting bribes intended for the employee’s benefit or that of the employee’s family, friends, associates or acquaintances.

No employees will suffer demotion, penalty, or other adverse consequences from his or her refusal to pay bribes even if such refusal may result in delay or loss of business.

Employees are strictly prohibited from directly or indirectly offering or giving anything of value to government officials, political candidates, business partners or anyone else to obtain an undue advantage for ISF Group Limited.
Participating in corruption in any form such as offering or accepting bribes will lead to disciplinary actions, and in extreme situations, dismissal of the employee.

The only exception is if you are faced with a life-threatening situation. In such case the payment must be approved by Legal Department. Under the circumstances that there is not time for contacting Legal Department, the situation must be reported immediately to Legal Department when solved.

2.2 Money Laundering

Money laundering is the process by which large amounts of illegally obtained money (e.g. from drug trafficking) are given the appearance of having originated from a legitimate business.

ISF Group Limited only does business with business partners and customers with legitimate businesses.

Before entering into business with new partners, this must be checked out carefully.

2.3 Facilitation Payments

Facilitation payments are small cash payments made to secure or speed up administrative actions, processes or documents, obtaining mail or telephone services, or expediting shipments through customs. The payment is not intended to influence the outcome of the official's action, only its timing.

ISF Group Limited does not endorse facilitation payments and advises, where possible, to attempt avoid making facilitation payments.

2.4 Charitable Contributions and Sponsorships

Charitable contributions and sponsorships must not be used as bribery or any private advantages such as rebated purchase or sponsorship from business partners. It is important to act objectively and professionally, and keep all private matters aside when interacting with business partners.

2.5 Gifts, Entertainment and Favours

It is common business courtesy in many countries for guests and hosts to offer or accept gifts. ISF Group Limited accepts this as part of the culture and does not wish to embarrass others who follow these customs. Gifts can include objects, events, entertainment or favours.

Gifts should be offered and accepted only as common social or business courtesy at a level appropriate to the status and seniority of those involved. Any gifts or favours interpreted as an attempt to encourage preferential treatment are not acceptable under any circumstances.

The limit for a gift is to be determined by the local management of each business unit up to a maximum of £30. Any gift to be given that is worth more than the agreed limit requires prior approval by the ISF Group Limited Managing Board member responsible for the area inquisition and must be registered.

Gifts received with a value over £30 must be handed over to the business units’ HR manager. If possible, these gifts will be made available for everyone and otherwise be donated to charity or similar. Exceptions would be a gift to celebrate an employee’s anniversary with the company or birthday.