Anti-Bribery and Whistleblowing Policy

1. Introduction

Hambleton UK Ltd ("the Company") is committed to conducting business with integrity, transparency, and accountability. This policy outlines our stance on bribery and corruption and provides guidance on how employees and other stakeholders can report unethical behaviour through whistleblowing channels.

2. Purpose

The purpose of this policy is to:

• · Set out the Company’s position on bribery and corruption.
• · Provide clear guidance on what constitutes bribery.
• · Outline procedures for reporting concerns related to bribery, corruption, or any other unethical behaviour.
• · Protect whistleblowers from retaliation.

3. Scope

This policy applies to all employees, directors, officers, consultants, contractors, and any other third parties acting on behalf of the Company, regardless of their location or function.

4. Anti-Bribery Policy

4.1 Definition of Bribery

Bribery is the offering, giving, receiving, or soliciting of something of value as a means of influencing the actions of an individual in a position of trust or to gain an undue advantage.

4.2 Prohibition of Bribery

• · The Company prohibits all forms of bribery, whether direct or indirect.
• · No employee or associated person shall offer, promise, give, request, agree to receive, or accept a bribe.
• · Bribery in any form is strictly prohibited whether it involves public officials or private individuals.

4.3 Gifts and Hospitality

• · Gifts and hospitality should be offered and accepted only when they are reasonable, proportionate, and made in good faith.
• · Gifts or hospitality intended to exert undue influence or secure an improper advantage are prohibited.
• · Employees must seek approval from their line manager before giving or receiving any gift or hospitality that exceeds a nominal value set by the Company.

4.4 Facilitation Payments

Facilitation payments, which are small, unofficial payments made to expedite routine government actions, are strictly prohibited.

4.5 Donations and Sponsorships

Donations and sponsorships must be transparent, properly recorded, and must not be used as a cover for bribery.

5. Whistleblowing Policy

5.1 Definition of Whistleblowing

Whistleblowing refers to the act of reporting concerns about illegal, unethical, or improper conduct within the Company, including but not limited to bribery, corruption, fraud, health and safety violations, and environmental damage.

5.2 Reporting Procedure

• · Employees and other stakeholders are encouraged to report any concerns or suspicions of bribery, corruption, or unethical behavior as soon as possible.
• · Reports can be made through the following channels:
• o Directly to the immediate line manager.
• o To the HR department.
• o Via the confidential whistleblowing hotline/email: rm@hambletonuk.com
• · Reports can be made anonymously, though providing contact details will assist in further investigation.

5.3 Protection of Whistleblowers

• · The Company is committed to protecting whistleblowers from retaliation or victimization.
• · Any form of retaliation against a whistleblower is prohibited and will be subject to disciplinary action.
• · Whistleblowers will not face any negative consequences for reporting concerns in good faith, even if the report turns out to be incorrect.

5.4 Confidentiality

All whistleblowing reports will be treated with the utmost confidentiality. Information will only be shared on a need-to-know basis and as required by law.

5.5 Investigation Process

• · The Company will investigate all reports of bribery, corruption, or unethical behavior promptly and thoroughly.
• · The investigation will be conducted impartially, respecting the rights of all parties involved.
• · Appropriate action will be taken based on the findings of the investigation, which may include disciplinary action, legal action, or changes to Company policies and procedures.

6. Responsibilities

6.1 Employees

• · All employees are required to read, understand, and comply with this policy.
• · Employees must report any suspected bribery or unethical behavior immediately.

6.2 Management

• · Managers are responsible for ensuring that employees understand and comply with this policy.
• · Management must take appropriate action when concerns are raised, including supporting the investigation process.

6.3 The Company

• · The Company is responsible for providing adequate training and resources to ensure the effective implementation of this policy.
• · The Company will regularly review and update this policy to ensure its effectiveness.

7. Training and Communication

• · The Company will provide regular training on anti-bribery and whistleblowing policies to all employees.
• · This policy will be communicated to all employees, contractors, and relevant third parties and made available on the Company’s intranet and website.

8. Monitoring and Review

• · The Company will monitor compliance with this policy and review its effectiveness annually or as necessary.
• · Any updates or changes to this policy will be communicated to all employees and relevant stakeholders.

9. Consequences of Non-Compliance

• · Any employee found to have engaged in bribery or corruption will face disciplinary action, which may include termination of employment.
• · Violations of this policy may also result in legal action and significant penalties for both the individual and the Company.

10. Contact Information

For any questions regarding this policy or to report concerns, please contact:

Human Resources Department Hambleton UK Ltd Email: rm@hambletonuk.com