1. Scope

1.1. All employees, contractors and any person or body acting on behalf of Land Technologies Ltd. (Company) or any of its subsidiaries will be within the scope of this policy.

2. Responsibilities

2.1. The Head of People is responsible for ensuring all employees and associated persons are familiarised with this policy as part of their induction process and for ensuring this policy is kept up to date.

2.2. Employees and, where applicable, associated persons, are required to fully read and comply with the provisions of this policy

3. Principles

3.1. The Company prohibits employees or associated persons from offering, promising, giving, soliciting or accepting any bribe. The bribe might be cash, a gift or other inducement to, or from, any private person or company, regardless of where the employee or associated person is situated.

3.2. This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or subcontractors, agents or sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.

3.3. The Company permits corporate entertainment, gifts, hospitality and promotional expenditure that is undertaken:

for the purpose of establishing or maintaining good business relationships;
to improve the image and reputation of the Company; or
to present the Company's product/s and service effectively;

This is provided that it is:

arranged in good faith, and
not offered, promised or accepted to secure an advantage for the Company or any of its employees or associated persons or to influence the impartiality of the recipient.

4. Procedure

4.1 Particular care must be taken to ensure that all Company records are accurately maintained in relation to any contracts or business activities, including financial invoices and all payment transactions with clients, suppliers and public officials.

4.2 Records of all corporate hospitality, entertainment or gifts accepted or offered must be accurate, detailed and be up-to-date.

4.3 Employees and, where relevant, associated persons should submit requests for proposed hospitality and promotional expenditure well in advance of proposed dates to their Line Manager who will then forward this request to the relevant department.

4.4 Requests for proposed hospitality and promotional expenditure must include:

the objective of the proposed client entertainment or expenditure;
the identity of those who will be attending and the company they represent; and
details and rationale of the proposed activity.

4.5 Any suspicions of, or actual attempts of, bribery or conflicts of interest must be reported to the Head of People and/or the Chief Executive Officer. If in any doubt as to whether or not a potential act constitutes bribery, the matter should be referred to the Head of People and/or the CEO.

4.6 Any direct or indirect request for payment by a public official must be detailed in writing by said public official. If the public official refuses to give these, this should be reported immediately to the Head of People and/or the CEO.

4.7 Employees who report instances of bribery in good faith will be supported by the Company. The Company will ensure that the individual is not subjected to detrimental treatment as a consequence of their report. Any instances of detrimental treatment by a fellow employee because an employee has made a report will be treated as a disciplinary offence.

4.8 The Company will fully investigate any instances of alleged or suspected bribery. Employees suspected of bribery may be suspended from their duties while the investigation is being carried out.

4.9 The Company will invoke its disciplinary procedures where any employee is suspected of bribery, and proven allegations may result in a finding of gross misconduct and immediate dismissal.

4.10 Where necessary to do so, such as for legal compliance, the Company may report any matter to the relevant authorities and provide assistance to the relevant authorities in any subsequent prosecution.