Serac Technologies Ltd Comprehensive Anti-Bribery and Corruption Policy

1. Introduction

Serac Technologies Ltd steadfastly commits to conducting its business operations and activities globally with the highest principles of ethical conduct, integrity, and adherence to the law. This Comprehensive Anti-Bribery and Corruption Policy is a cornerstone of our ethical framework, designed to prevent, detect, and address bribery and corruption in all forms within our operations and among all persons and entities associated with or acting on behalf of our company.

2. Purpose

The purpose of this policy is to set out clear guidelines and principles to prevent acts of bribery and corruption. It aims to ensure that Serac Technologies Ltd and all its Representatives understand the risks associated with bribery and corruption and are equipped to act ethically and in compliance with all applicable laws, including the UK Bribery Act 2010 and similar international anti-corruption laws.

3. Scope

This policy applies to all employees, officers, directors, consultants, contractors, interns, agents, and any other individuals or entities (including third parties, such as suppliers, partners, and joint ventures) acting on behalf of Serac Technologies Ltd, globally.

4. Definitions

Bribery: The act of offering, giving, receiving, or soliciting something of value as an inducement for an action which is illegal, unethical, or a breach of trust.
Corruption: The abuse of entrusted power for private gain.

5. Policy Statements

- Zero Tolerance for Bribery and Corruption: Serac Technologies Ltd adopts a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships.
- Prohibition of Bribery: No Representative of Serac Technologies Ltd shall engage in any form of bribery, whether directly or indirectly. This prohibition extends to offering, promising, giving, accepting, or soliciting any form of bribe for any purpose.
- Gifts, Hospitality, and Expenses: Gifts and hospitality are acceptable within the bounds of reasonableness and legality, provided they are not intended to influence a business decision or gain an unfair advantage. This policy outlines clear thresholds for the value of gifts and hospitality and requires disclosure and prior approval for anything exceeding these thresholds.
- Facilitation Payments and Kickbacks: Facilitation payments, also known as "grease payments" or "expediting payments," made to secure or expedite routine government actions, are strictly prohibited, as are kickbacks from any third party in exchange for any form of preferential treatment or business advantage.
- Due Diligence: Serac Technologies Ltd will conduct due diligence on all third parties prior to entering into any business relationships to assess the risk of bribery and corruption. This includes evaluating the third party’s reputation, ownership structure, and their commitment to anti-bribery and anti-corruption compliance.
- Training and Communication: All Representatives will receive comprehensive training on this policy and the risks of bribery and corruption relevant to their roles. This policy will be communicated to all business partners and made available to the public.
- Reporting and Whistleblowing: Representatives and external parties are encouraged to report any suspicion of bribery or corruption through our confidential reporting channels. Serac Technologies Ltd guarantees that no individual will suffer detriment, retaliation, or harassment for raising concerns in good faith.
- Record-Keeping: Accurate and complete records of all financial transactions must be maintained to evidence the business reasons for payments made and received. False, misleading, incomplete, or unrecorded accounts are prohibited.
- Monitoring, Review, and Enforcement: Regular audits and reviews will be conducted to ensure compliance with this policy. Non-compliance will be addressed with appropriate disciplinary measures, which may include termination of employment or business relationships and legal action.
- Management Responsibility: Leadership at all levels is responsible for ensuring those reporting to them understand and comply with this policy. They are to act as role models in the ethical conduct of business.

6. Approval and Review

This policy was approved by the Board of Directors of Serac Technologies Ltd on 22/02/2024 and is subject to annual review to ensure its continued relevance and effectiveness.

7. Policy Governance

This policy is governed by the Legal and Compliance Department of Serac Technologies Ltd, which is responsible for its implementation, monitoring compliance, and providing guidance and training to ensure understanding and adherence.

For and on behalf of Serac Technologies Ltd:
Brandon Johnson - Director
Date: 22/02/2024
Registered Office: Aston House, Cornwall Avenue, London, N3 1LF
Registered in England - Number 12258456
Telephone: 0203 808 6992