The UK Bribery Act 2010 makes it illegal for a commercial organisation to give or receive a bribe and also not to have implemented preventive procedures. The penalties for non-compliance are prison sentences and unlimited fines.

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Contractair Ltd has devised and implemented an Anti-bribery policy and provided awareness training of its requirements to all its employees.

It is Contractair policy to conduct all of its business in an honest and ethical manner. Contractair take a zero-tolerance approach to bribery and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships wherever Contractair operates; and implementing and enforcing effective systems to counter bribery.

Contractair does not permit the making of any inappropriate promises, or gifts, to others in order to achieve unfair advantage or benefit.

Contractair resists any efforts made by others (particularly existing or potential suppliers, customers or clients) to affect any Contractair decision making process in order to achieve unfair advantage or benefit.

Contractair commits to always reporting and/or documenting any suspicions of non-compliance with this policy through the reporting mechanism provided.

Contractair does not make contributions to political parties. Contractair may make charitable donations when they are ethical and legal under local laws and practices.

This policy is supported by additional policies - Business Gifts and Hospitality, Whistle blowing, Grievances, and Disciplinary Dismissal.

All policies are available to all staff via the intranet.

Any employee found to have contravened the Anti-bribery policy will be subject to the Disciplinary Dismissal policy which may find the contravention to be gross misconduct and the person concerned summarily dismissed.

SDB0286.1_CA