Version: 1.2

Effective date: 1st November 2023

INTRODUCTION
COPE is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business activities. One of the COPE’s core values ‘Finance andGovernance’ is to uphold responsible and fair business practices. We regard governance, transparency and accountability to be key in creating a culture of regulatory compliance. COPE takes a zero-tolerance approach to bribery and corruption and have implemented and effective systems to counter bribery including:

• Implementing a communication plan to make all employees aware of our anti-bribery
  and corruption policy;

• Assessing the risk of bribery and corruption within all operations and any new operations

• Inform all relevant employees so that they can recognise and avoid potentially corrupt or
  unethical practices

• Encouraging its employees to be vigilant in for potentially corrupt or unethical practices
  by others

• Providing them with clear, easy and anonymous mechanisms for reporting suspected unethical practices – including a Whistleblowing Policy

• Rigorously investigating instances of alleged bribery or corruption and assisting the police and other appropriate authorities in any resultant prosecution; and

• Taking vigorous action against anyone identified as being involved in bribery or corruption or similar unethical activities

SCOPE
This Policy applies to all permanent and temporary employees of COPE (including any of its intermediaries, subsidiaries or associated companies). It also applies to any individual or corporate entity associated with COPE or who performs functions in relation to, or for and on behalf of, COPE, including, but not limited to, directors, agency workers, casual workers, contractors, consultants, seconded staff, agents, suppliers and sponsors (“associated persons”). All employees and associated persons are expected to adhere to the principles set out in this Policy.

DEFINITIONS
Bribery is the offering, promising, giving, solicitation or the receipt or agreement to receive any financial or other advantage, or any other inducement from any person or company, (wherever they are situated and whether they are a public official or body, or a private person or company), by an individual employee, agent or other person or body acting on another’s behalf. Corruption – Corruption is the abuse of entrusted power for a private gain. COPE prohibits:

• Bribery of or by any person or company, in any jurisdiction, wherever they are situated and whether they are a public official or body or private person or company or by any individual employee, agent or other person or body acting on COPE’s behalf in order to:

• Gain any commercial, contractual or regulatory advantage for the Group in a way which is unethical or

• Gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual or

• Induce the improper performance of any function that is of a public nature, connected with a business, performed by a body or performed by a person in the course of their employment.

LEGAL CONTEXT
The UK legislation on which this Policy is based is the Bribery Act 2010 and it applies to the COPE’s conduct both in the UK and abroad. Bribery is a criminal offence in the UK and therefore illegal to:

• Offer, promise or give a financial or other advantage to another person (i.e. bribe a person), whether within the UK or abroad, with the intention of inducing or rewarding improper conduct

• Request, agree to receive or accept a financial or other advantage (i.e. receive a bribe) for or in relation to improper conduct

• Bribe a foreign public official.
  

You can be held personally liable for any such offence. It is also an offence in the UK for an employee or an associated person to bribe another person in the course of doing business intending either to obtain or retain business, or to obtain or retain an advantage in the conduct of business, for COPE. COPE can be liable for this offence where it has failed to prevent such bribery by associated persons. As well as an unlimited fine, it could suffer substantial reputational damage.

POLICY PROVISIONS
All employees and associated persons are required to:

• Comply with all anti-bribery and anti-corruption legislation

• Act honestly, responsibly and with integrity

• Safeguard and uphold the COPE’s core values by operating in an ethical, professional and lawful manner at all times.

Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a bribe. We recognise that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this Policy is expected of all employees and associated persons at all times. If in doubt as to what might amount to bribery or what might constitute a breach of this Policy, refer the matter to your line manager or to the Operations Director. The giving of business gifts to clients, customers, contractors and suppliers is not prohibited
provided the gift is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage. In addition any gift must be approved in advance by a Director of COPE and must:

• Comply with local laws

• Be given in COPE’s name, not in the giver’s personal name

• Be given openly, not secretly
  

Any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government procedure or process, otherwise known as a “facilitation payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are common in some other jurisdictions. This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are adequately recorded:

• Normal and appropriate hospitality;

• The giving of a ceremonial gift of token value on a festival or at another special time;

• The use of any recognised fast-track process which is available to all on payment of a
  fee

RESPONSIBILITIES AND REPORTING PROCEDURE
It is the contractual duty and responsibility of all employees and associated persons to take whatever reasonable steps are necessary to ensure compliance with this Policy and to prevent, detect and report any suspected bribery or corruption in accordance with the procedure set out in the Whistleblowing Policy.

COPE will support and protect anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. It is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future.

RECORD KEEPING
All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off the record” to facilitate or conceal improper payments.

SANCTIONS FOR BREACH
A breach of any of the provisions of this Policy will constitute a disciplinary offence and will be dealt with in accordance with the Disciplinary Procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could lead to summary dismissal. As far as associated persons are concerned, a breach of this Policy could lead to the suspension or termination of any relevant contract, sub-contract or other agreement.

COMMUNICATION
COPE will brief all employees to help them understand their duties and responsibilities under this Policy. COPE’s zero tolerance approach to bribery will also be communicated to all business partners at the outset of the business relationship with them and as appropriate thereafter. As the law is constantly changing, this policy is subject to review and COPE reserves the right to amend this policy without prior notice.