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Anti Corruption and Bribery Policy

Policy Statement

It is the policy of Bia Analytical to conduct our business in an open, honest and transparent way. We do not condone in any way the use of corrupt practices or acts of bribery to obtain an unfair advantage. We adhere to the highest ethical standards and this is reflected in every aspect of the way in which we operate. The Company will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business.

Who it Applies to

This policy applies to all individuals working for or on behalf of the Company (Workers) at all levels and grades, whether permanent, fixed-term or temporary, and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of the Company.

What is bribery?

A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence, namely:

  • Gifts and Hospitality: This policy does not prohibit normal and appropriate gifts and hospitality. The Company appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered. If unsure, check first with your line manager. Any gift received or given, and hospitality received or given should be recorded on the yearly declaration of Gifts & Hospitality.
  • giving or offering a bribe;
  • receiving or requesting a bribe; or
  • bribing a foreign public official.

What is not acceptable

It is not acceptable for any Worker (or someone on their behalf) to:

  • give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or the Company will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
  • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;
  • accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;
  • accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by the Company in return;
  • threaten or retaliate against another Worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
  • engage in any activity that might lead to a breach of this policy

Responsibilities

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy. Workers are required to notify the CEO as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee Workers if they breach this policy.

If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with the CEO, Richard Ilsley at Richard.ilsley@qub.ac.uk or directly with a member of the Executive Board.


The Modern Slavery Act 2015

The Modern Slavery Act 2015 has introduced changes in UK law focused on increasing transparency in supply chains. Specifically, large businesses will be required to disclose the steps they have taken to ensure their business and supply chains are free from modern slavery (that is, slavery, servitude, forced and compulsory labour and human trafficking). “Commercial organisations” (body corporates or partnerships carrying on any part of their business in the UK) that supply goods or services and have a minimum turnover of £36 million will be required to produce a “slavery and human trafficking statement” each financial year. This is a statement of the steps (if any) taken to ensure modern slavery is not taking place in the organisation’s own business and its supply chains (this does not mean the organisation must guarantee the entire supply chain is slavery free). The statement will be approved by the board and signed by a director. The statement will also be published on our website.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

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