Anti-Corruption and Bribery Policy

1.1 This policy is designed to help Gold Bank London and its employees maintain compliance with the Act and ensure exemplary practice in relation to conduct of business with third parties, suppliers and customers.

1.2 Gold Bank London aim to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.

1.3 We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

2.1 Bribery – Giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having done so.

2.2 Corruption – The misuse of public office or power for private gain; or misuse of private power in relation to conducting day to day activity.

3.1 An offence is committed where a person associated with the organisation (e.g. an employee of Gold Bank London) commits an act of corruption with the intention of obtaining or retaining business or of obtaining or retaining an advantage in the conduct of business.

3.2 Specifically prohibited conduct includes:

3.3 It is also an offence for the organisation (i.e. Gold Bank London) to fail to prevent bribery by persons associated with the organisation. Bribery is illegal; being involved in bribery is not just limited to the act of offering a bribe: if you are on the receiving end and accept it, you are also breaking the law.

4.1 The purpose of this policy is to:

4.2 It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years' imprisonment and/or a fine. As an employer, if we fail to prevent bribery we can face an unlimited fine and damage to our reputation. We therefore take our legal responsibilities very seriously.

4.3 In this policy, third party means any individual or organisation you come into contact with during the course of your work at Gold Bank London, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

5.1 This Anti-bribery & Corruption Policy applies to all Gold Bank London staff and directors and including staff and directors of any subsidiary or associated companies. The policy also includes third parties such as agency workers, consultants, sub-contractors and others working on behalf of Gold Bank London, irrespective of their location, function or grade.

5.2 Gold Bank London does not wish to stifle the development of good working relationships with suppliers, agents, contractors or officials; however, the actions must be transparent, proportionate and auditable.

5.3 Gold Bank London expects our business partners, agents, suppliers and contractors to act with honesty and integrity and without any actions that may be considered as an offence within the meaning of the Bribery Act 2010.

5.4 Gold Bank London employees or any other person working on behalf of Gold Bank London must not:

5.5 Offer or make a bribe, unauthorised payment or inducement of any kind to anyone;

5.6 Gold Bank London employees or any other person working on behalf of Gold Bank London must:

6.1 The Bribery Act requires that adequate measures are in place to prevent bribery using six guiding principles. Each of these principles are considered in light of the nature, size and complexity of Gold Bank London. Therefore, the principles of this policy are as follows:

7.1 The acceptance of gifts, services and hospitality is related to the issue of conflicts of interest and can leave Gold Bank London vulnerable to accusations of unfairness, partiality or deceit. Its commercial relationships may be subject to bias and its ethical reputation will be at risk.

7.2 The occasional exchange of business gifts, meals or low level entertainment is a common practice and is meant to create goodwill and enhance relationships. However, if the receipt of business courtesies becomes excessive, it can create a sense of personal obligation on the part of the recipient.

7.3 Such sense of obligation can interfere with the individual's ability to be impartial in the transaction. Staff may accept business courtesies, but such courtesies must be modest enough not to interfere with the ethical judgment of the member of staff and must not be inappropriate or create an appearance of impropriety.

7.4 Corporate hospitality and gifts (whether received or provided) must be transparent, auditable and proportionate. Modest gifts and hospitality may be accepted in line with the Gold Bank London Gifts and Hospitality Procedure unless an inducement is intended or suspected.

7.5 If a gift or hospitality is not in keeping with circumstances then every effort must be made to refuse the offer without offending the person or organisation making the offer.

7.6 Any gift or hospitality received or given must not have any influence or have been intended to influence the party receiving the gift or hospitality.

7.7 All hospitality and gifts should only be accepted if they are in line with the Gold Bank London Gifts and Hospitality Procedure.

8.1 Gold Bank London takes compliance with the act very seriously and any known or perceived breach of the Policy or act should be reported immediately to the Head of Compliance & Risk.

8.2 Staff must not receive offers, solicitations or accept any bribe or inducement that contravenes the Bribery Act 2010. Gold Bank London will identify areas of potential risk and put appropriate processes in place to mitigate them.

8.3 Any breach of the procedure, policy or law will be treated as a disciplinary offence and may result in dismissal.

8.4 In the event that a person to whom this policy applies feels that either the investigation of the breach or their relationship with any colleague might be compromised by reporting the breach internally, they should contact Gold Bank London's Head of Compliance & Risk.

8.5 Anyone who reports a violation of this policy or the Act will then be protected from retaliation in any form.

9.1 Representatives and staff of Gold Bank London should understand this policy and procedure in addition to the following.

9.2 Managers are asked to:

9.3 Members of staff and representatives of Gold Bank London are asked to: