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Anti-Bribery Policy

1. Purpose

1.1 CYBER RESILIENCE CENTRE FOR LONDON LIMITED, a company incorporated in 
England and Wales, (Registered No.13897995) with its Registered Office at 4 
Quinton Parade, Cheylesmore, Coventry, England, CV3 5HW (“the
Company”) is committed to the practice of responsible corporate behaviour
and to complying with all laws, regulations and other requirements which
govern the conduct of our operations.
1.2 The Company is fully committed to instilling a strong anti-corruption culture
and is fully committed to compliance with all anti-bribery and anti-corruption
legislation including, but not limited to, the Bribery Act 2010 (“the Act”) and
ensures that no bribes or other corrupt payments, inducements or similar are
made, offered, sought or obtained by us or anyone working on our behalf.


2. Bribery

2.1 Bribery is defined as the giving or promising of a financial or other advantage
to another party where that advantage is intended to induce the other party to
perform a particular function improperly, to reward them for the same, or
where the acceptance of that advantage is in itself improper conduct.
2.2 Bribery is also deemed to take place if any party requests or agrees to receive
a financial or other advantage from another party where that advantage is
intended to induce that party to perform a particular function improperly, where
the acceptance of that advantage is in itself improper conduct, or where that
party acts improperly in anticipation of such advantage.
2.3 Bribery of a foreign official is defined as the giving or promising of a financial
or other advantage which is intended to influence the official in order to obtain
business or an advantage in the conduct of business unless the foreign official
is required or permitted by law to be influenced by such advantage.


3. Consequences of Bribery

3.1 Anyone or any organisation found guilty of bribery under the Act may face
fines and/or prison terms. In addition, high legal costs and adverse publicity
are likely to result from any breach of the Act.
3.2 For employees of the Company, failure to comply with this Policy and/or with
the Act may result in:
3.2.1 disciplinary action which may include dismissal; and
3.2.2 criminal penalties under the Act which may result in a fine and/or
imprisonment for up to 10 years.
3.3 For the Company, any breach of this Policy by any employee or business
associate may result in:
3.3.1 the Company being deemed to be in breach of the Act;
3.3.2 the Company being subject to fines; and
3.3.3 the Company suffering negative publicity and further associated
damage as a result of such breach.


4. Responsibility for Compliance and Scope of Policy

4.1 This Policy applies to all employees, agents, contractors, subcontractors,
consultants, business partners and any other parties (including individuals,
partnerships and bodies corporate) associated with the Company or any of its
subsidiaries.
4.2 It is the responsibility of all of the abovementioned parties to ensure that
bribery is prevented, detected and reported and all such reports should be
made in accordance with the Company’s Whistleblowing Policy or as
otherwise stated in this Policy, as appropriate.
4.3 No party described in section 4.1 may:
4.3.1 give or promise any financial or other advantage to another party (or
use a third party to do the same) on the Company’s behalf where that
advantage is intended to induce the other party to perform a particular
function improperly, to reward them for the same, or where the
acceptance of that advantage will in itself constitute improper conduct;
4.3.2 request or agree to receive any financial or other advantage from
another party where that advantage is intended to induce the improper
performance of a particular function, where the acceptance of that
advantage will in itself constitute improper conduct, or where the
recipient intends to act improperly in anticipation of such an advantage.
4.4 Parties described in section 4.1 must:
4.4.1 be aware and alert at all times of all bribery risks as described in this
Policy and in particular as set out in section 9 below;
4.4.2 exercise due diligence at all times when dealing with third parties on
behalf of the Company; and
4.4.3 report any and all concerns relating to bribery to your line manager or a
member of the Company’s Board or, in the case of non-employees,
their normal point of contact within the Company, or otherwise in
accordance with the Company’s Whistleblowing Policy.


5. Facilitation Payments

5.1 A facilitation payment is defined as a small payment made to officials in order
to ensure or speed up the performance of routine or necessary functions.
5.2 Facilitation payments constitute bribes and, subject to section 5.3, may not be
made at any time irrespective of prevailing business customs in certain
territories.
5.3 Facilitation or similar payments may be made in limited circumstances where
your life is in danger but under no other circumstances. Any payment so
made must be reported to your line manager or a member of the Company’s
Board as soon as is reasonably possible and practicable.


6. Gifts and Hospitality

6.1 Gifts and hospitality remain a legitimate part of conducting business and
should be provided only in compliance with the Company’s Gifts and
Hospitality Policy.
6.2 Gifts and hospitality can, when excessive, constitute a bribe and/or a conflict
of interest. Care and due diligence should be exercised at all times when
giving or receiving any form of gift or hospitality on behalf of the Company.
6.3 The following general principles apply:
6.3.1 Gifts and hospitality may neither be given nor received as rewards,
inducements or encouragement for preferential treatment or
inappropriate or dishonest conduct.
6.3.2 Neither gifts nor hospitality should be actively sought or encouraged
from any party, nor should the impression be given that the award of
any business, custom, contract or similar will be in any way conditional
on gifts or hospitality.
6.3.3 Cash should be neither given nor received as a gift under any
circumstances.
6.3.4 Gifts and hospitality to or from relevant parties should be generally
avoided at the time of contracts being tendered or awarded.
6.3.5 The value of all gifts and hospitality, whether given or received, should
be proportionate to the matter to which they relate and should not be
unusually high or generous when compared to prevailing practices in
our industry or sector.
6.3.6 Certain gifts which would otherwise be in breach of this Policy and/or
the Hospitality and Gifts Policy may be accepted if refusal would cause
significant and/or cultural offence, however the Company will donate
any gifts accepted for such reasons to a charity of the Company’s
Board’s choosing.
6.3.7 All gifts and hospitality, whether given or received, must be recorded in
the Hospitality & Gifts Register.


7. Charitable Donations

7.1 Charitable donations are permitted only to registered (non-profit) charities. No
charitable donations may be given to any organisation which is not a
registered charity. The Company is not a charity. No charitable donations are
to be received and if offered inform your line manager or a member of the
Company’s Board
7.2 All charitable donations must be fully recorded in the Hospitality and Gifts
Register.
7.3 Proof of receipt of all charitable donations must be obtained from the recipient
organisation.
7.4 Under no circumstances may charitable donations be made in cash.
7.5 No charitable donation may be made at the request of any party where that
donation may result in improper conduct.

8. Political Donations

8.1 The Company does not make political donations and the Company is not
affiliated with any political party, independent candidate, or with any other
organisation whose activities are primarily political.
8.2 Employees and other associated parties are free to make personal donations
provided such payments are not purported to be made on behalf of the
Company and are not made to obtain any form of advantage in any business
transaction.


9. Due Diligence and Risks

The following issues should be considered with care in any and all transactions,
dealings with officials, and other business matters concerning third parties:
9.1 Territorial risks, particularly the prevalence of bribery and corruption in a
particular country;
9.2 Cross-border payments, particularly those involving territories falling under
section 9.1;
9.3 Requests for cash payment, payment through intermediaries or other unusual
methods of payment;
9.4 Activities requiring the Company and / or any associated party to obtain
permits or other forms of official authorisation;
9.5 Transactions involving the import or export of goods.