1. What does your policy cover?

This anti-bribery policy exists to set out the responsibilities of exe and those who work for us in regard to observing and upholding our zero-tolerance position on bribery and corruption.
It also serves as a source of information and guidance for those working for exe It helps them to recognize and deal with bribery and corruption issues, as well as understand their responsibilities.

2. Policy statement

exe is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. exe has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.
exe will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate.
exe recognises that bribery and corruption are punishable. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.

3. Who is covered by the policy?

This anti-bribery policy applies to all employees, consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are.
In the context of this policy, third-party refers to any individual or organization with whom our company meets and works. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public authorities – this includes their advisors, representatives and officials, politicians, and public parties.
Any arrangements our company makes with a third party are subject to clear contractual terms, including specific provisions that require compliance by the third party.

4. Definition of bribery

Bribery refers to the act of offering, giving, promising, asking for, agreeing, receiving, accepting, or soliciting something of value or of an advantage so as to induce or influence an action or decision.
A bribe refers to any inducement, reward or object/item of value offered to another individual in order to gain commercial, contractual or personal advantage.
Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.

5. What is and what is NOT acceptable

This section of the policy refers to 3 areas:

  • Gifts and hospitality.
  • Facilitation payments.
  • Political contributions.
  • Gifts and hospitality

exe accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) 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, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
  • It is not made with the suggestion that a return favour is expected.
  • It is in compliance with local law.
  • It is given in the name of the company, not in an individual’s name.
  • It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
  • It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
  • It is given/received openly, 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 pre-determined by the company’s officer (100 EUR).
  • It is not offered to, or accepted from, a government official or representative, or politician or political party, without the prior approval of the company’s compliance manager.

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who might want to share), the gift may be accepted as long as it is declared to the compliance manager who will assess the circumstances.

Facilitation Payments and Kickbacks
exe does not accept and will not make any form of facilitation payments of any nature. We recognize that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
exe does not allow kickbacks to be made or accepted.

Political Contributions
exe will not make donations, whether in cash, payment in kind, or by any other means to support any political parties or candidates. We recognise this could be perceived as an attempt to gain an improper business advantage.

6. Employee Responsibilities

As an employee of exe you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.
All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to or imply a breach of this anti-bribery policy.
If you have reason to believe or suspect that an instance of bribery or corruption has occurred or is to occur in the future that breaches this policy, you must notify the compliance manager.
If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. exe has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.

7. What happens if I need to raise a concern?

This section of the policy covers 3 areas:

How to raise a concern
If you suspect that there is an instance of bribery or corrupt activities occurring in relation to exe, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal.

What to do if you are a vicitim of bribery or corruption
You must tell your manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

Protection
If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, exe understands that you may feel worried about potential repercussions. exe will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.
exe will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.
Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.
If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager immediately.

8. Training and communication

exe will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular and relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.

exe’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties.