Anti-Bribery Policy

Anti-Bribery Policy

1. Policy statement
   1.1 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.
   1.2 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 our contractors, suppliers and other business partners.
   1.3 This policy applies to all persons working for us or on our behalf in any capacity,
   including employees at all levels, directors, officers, agency workers, seconded workers,
   volunteers, interns, agents, contractors, external consultants, third-party representatives
   and business partners.
   1.4 This policy does not form part of any employee’s contract of employment and we may
   amend it at any time.

2. Responsibility for the policy
2.1 The Managing Director has overall responsibility for ensuring this policy complies with
our legal and ethical obligations, and that all those under our control comply with it.
2.2 The Managing Director has primary and day-to-day responsibility for implementing this policy,
monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems
and procedures to ensure they are effective in countering modern slavery.
2.3 Management is responsible for ensuring those reporting to them understand and
comply with this policy and are given adequate and regular training on it and the issue of
modern slavery in supply chains.
2.4 You are invited to comment on this policy and suggest ways in which it
might be improved. Comments, suggestions and queries are encouraged and should
be addressed to: Info@Diabolicalgifts.com

3. Compliance with the policy
3.1 You must ensure that you read, understand and comply with this policy.
3.2 The prevention, detection and reporting of modern slavery in any part of our
business or supply chains is the responsibility of all those working for us or
under our control. You are required to avoid any activity that might lead to,
or suggest a breach of this policy.
3.3 You must notify the TDGP Managing Director as soon as possible if you believe
or suspect that a conflict with this policy has occurred or may occur in the
future.
3.4 You are encouraged to raise concerns about any issue or suspicion of modern
slavery in any parts of our business or supply chains of any supplier tier at the
earliest possible stage.
3.5 If you believe or suspect a breach of this policy has occurred or that it may
occur, we would ask that you please notify us as soon as possible.
3.6 If you are unsure about whether a particular act, the treatment of workers
more generally, or their working conditions within any tier of our supply chains
constitutes any of the various forms of modern slavery, raise it with us.
3.7 We aim to encourage openness and will support anyone who raises genuine
concerns in good faith under this policy.

4. Communication and awareness of this policy
   4.1 Our zero-tolerance approach to modern slavery in our business and supply
   chains is communicated to all suppliers, contractors and business partners at
   the start of our business relationship with them and reinforced as appropriate
   thereafter.

5. Breaches of this policy
   5.1 We may terminate our relationship with individuals and organisations working
   on our behalf if they breach this policy.

ANTI-BRIBERY POLICY:

1. What does this policy cover?
   1.1 This anti-bribery policy exists to set out the responsibilities of TDGP and those
   who work for us regarding observing and upholding our zero-tolerance position
   with reference to bribery and corruption.
   1.2 It also exists to act as a source of information and guidance for those working
   for TDGP. It helps them recognise and deal with bribery and corruption issues, as
   well as understand their responsibilities.

2. Policy statement
   2.1 TDGP is committed to conducting business in an ethical and honest way, and is
   committed to implementing and enforcing systems that ensure bribery is prevented.
   TDGP has zero-tolerance for bribery and corrupt activities. We are committed to
   acting professionally, fairly and with integrity in all business dealings and
   relationships, wherever in the country we operate.
   2.2 TDGP will constantly uphold all laws relating to anti-bribery and corruption in all
   The jurisdictions in which we operate. We are bound by the laws of the UK,
   including the Bribery Act 2010, in regards to our conduct both at home and
   abroad.
   2.3 TDGP recognises that bribery and corruption are punishable by up to ten years of imprisonment
   and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected
   to an unlimited fine, be excluded from tendering for public contracts and face serious damage to our
   reputation. It is with this in mind that we commit to preventing bribery and corruption in our business
   and take our legal responsibilities seriously.

3. Who is covered by the policy?
   3.1 This anti-bribery policy applies to all officers, employees (whether temporary, fixed-term, or
   permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency
   staff, volunteers, interns, agents, sponsors or any other person or persons associated with us (including
   third parties) no matter where they are located (within or outside of the UK)
   3.2 In the context of this policy, third-party refers to any individual or organisation our
   company meets and works with. It refers to actual and potential clients, customers,
   suppliers, distributors, business contacts, agents, advisers and Government and Public
   bodies – this includes their advisors, representatives and officials, politicians and public parties.
   3.3 Any arrangements our company makes with a third party is subject to clear contractual
   terms, including specific provisions that require the third party to comply with minimum
   standards and procedures relating to anti-bribery and corruption.

4. Definition of bribery
   4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting or
   soliciting something of value or of an advantage so to induce or influence an action or decision.
   4.2 A bribe refers to any inducement, reward, or object / item of value offered to another
   individual in order to gain commercial, contractual, regulatory or personal advantage.
   4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving
   end of a bribe and they accept it, they are also breaking the law.
   4.4 Bribery is illegal. Officers and employees must not engage in any form of bribery, whether it
   be directly, passively or through a third party (such as an agent or distributor). They must
   not bribe a foreign public official anywhere in the world. They must not accept bribes in any
   degree and if they are uncertain about whether something is a bribe or a gift or act of
   hospitality, they must seek further advice from the company’s Managing Director.

5. What is and what is NOT acceptable
   5.1 This section of the policy refers to 4 areas:

• Gifts and hospitality
• Facilitation payments
• Political contributions
• Charitable contributions
  5.2 Gifts and hospitality
  TDGP accepts normal and appropriate gestures of hospitality and goodwill (whether
  given to / received from third parties) so long as the giving or receiving of gifts meets
  the following requirements:
• It is not made with the intention of influencing the party to whom it is being
  given, to obtain or reward the retention of a business or a business advantage or as
  an explicit or implicit exchange for favours or benefits.
• It is not made with the suggestion that a return favour is expected.
• It is in compliance with local laws
• It is given in the name of the Company, not an individua’s name.
• It does not include cash or a cash equivalent (e.g.a voucher or gift certificate). It is
  appropriate for the circumstances. It is of an appropriate type and value and
  given at an appropriate time, taking into account the reason for the gift.
• It is given/received openly, not secretly.
• It is not selectively given to a key, influential person, clearly with the
  intention of directly influencing them.
• It is not above a certain excessive value, as pre-determined by the company’s
  Managing Director (usually in excess of £100).
• It is not offered to, or accepted from a government official or representative or
  politician or political party, without the prior approval of the company’s Managing
  Director.

5.2 Gifts and hospitality
TDGP accepts normal and appropriate gestures of hospitality and goodwill (whether
given to / received from third parties) so long as the giving or receiving of gifts meets
the following requirements:

• It is not made with the intention of influencing the party to whom it is being
  given, to obtain or reward the retention of a business or a business advantage or as
  an explicit or implicit exchange for favours or benefits.
• It is not made with the suggestion that a return favour is expected.
• It is in compliance with local laws
• It is given in the name of the Company, not an individua’s name.
• It does not include cash or a cash equivalent (e.g.a voucher or gift certificate). It is
  appropriate for the circumstances. It is of an appropriate type and value and
  given at an appropriate time, taking into account the reason for the gift.
• It is given/received openly, not secretly.
• It is not selectively given to a key, influential person, clearly with the
  intention of directly influencing them.
• It is not above a certain excessive value, as pre-determined by the company’s
  Managing Director (usually in excess of £100).
• It is not offered to, or accepted from a government official or representative or
  politician or political party, without the prior approval of the company’s Managing
  Director.

5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion / culture who may take offence), the gift may be accepted so long as it is declared to the Managing Director, who will assess the circumstances.

5.4 TDGP recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures and religions, so definitions of what may or may not be acceptable will inevitably differ for each.

5.5 As good practice, gifts given and received should always be disclosed to the Managing Director. Gifts from suppliers should always be disclosed.

5.6 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the Managing Director should be sought.

5.7 Facilitation Payments and Kickbacks:
(a) TDGP does not accept, will not make and will not work with any person or organisation which it
comes to be aware accepts or makes, any form of facilitation payments of any nature. We recognise that
facilitation payments are a form of bribery that involves expediting or facilitating the performance of a
public official for a routine governmental action.
(b) TDGP does not allow kickbacks to be made or accepted. We recognise that
kickbacks are typically made in exchange for a business favour or advantage.

5.8 Political Contributions: TDGP will not make donations, whether in cash, kind, or by
any other means, to support any political parties or candidates. We recognise this may
be perceived as an attempt to gain an improper business advantage.

5.9 Charitable Contributions: TDGP accepts (and indeed encourages) the act of
donating to charities-whether through services, knowledge, time or direct financial
contributions (cash or otherwise).

5.10 Employees and agents must be careful to ensure that charitable contributions are not
used to facilitate and conceal acts of bribery.

5.11 We will ensure that all charitable donations made are legal and ethical under local
laws and practices and that donations are not offered / made without the approval of
the Managing Director.

6. Employee and Agent Responsibilities
   6.1 As an employee or agent of TDGP, you must ensure that you read, understand
   and comply with the information contained within this policy, and with any training or
   other anti-bribery and corruption information you are given.
   6.2 All employees and agents are equally responsible for the prevention,
   detection reporting of bribery and other forms of corruption. They are required to avoid
   any activities that could lead to, or imply, a breach of this anti-bribery policy.
   6.3 If you have reason to believe or suspect that an instance of bribery or corruption
   has occurred or will occur in the future that breaches this policy, you must notify the
   Managing Director.
   6.4 If any employee or agent breaches this policy, they will face disciplinary action and
   could face termination of their relationship with TDGP.TDGP has the right to terminate a
   relationship with an employee or agent if they breach this anti-bribery policy.

7. What happens if I need to raise a concern?
7.1.1 This section of the policy covers 3 areas:
7.1.2 How to raise a concern
7.1.3 What to do if you are a victim of bribery or corruption
7.1.4 Protection
7.2 How to raise a concern
If you suspect that there is an instance of bribery or corrupt activities occurring in
relation to TDGP, you are encouraged to raise your concerns at as early a stage as
possible. If you’re uncertain about whether a certain action or behaviour can be
considered bribery or corruption, you should inform the Managing Director.
7.3 What to do if you are a victim of bribery or corruption.
You must tell the Managing Director as soon as possible if you are offered a bribe by
anyone, if you are asked to make one, if you suspect that you may be bribed or asked to
make a bribe in the near future or if you have reason to believe that you are a victim of
another corrupt activity.
7.4 Protection
If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of
bribery or corruption, TDGP understands that you may feel worried about potential
repercussions. TDGP will support anyone who raises concerns in good faith under this policy,
even if investigation finds that they were mistaken.

8. Record keeping
   TDGP will keep detailed and accurate financial records, and will have appropriate internal controls
   in place to act as evidence for all payments made. We will keep a written record of the amount
   and reason for hospitality or gifts accepted and given, and understand that gifts and acts of
   hospitality are subject to managerial review.
9. Monitoring and reviewing
   9.1 TDGP’s Managing Director is responsible for monitoring the effectiveness of this policy
   and will review the implementation of it on a regular basis. He / she will assess its
   suitability, adequacy and effectiveness.
   9.2 Employees and agents are encouraged to offer their feedback on this policy if they have a
   ny suggestions for how it may be improved. Feedback of this nature should be addressed to
   the Managing Director.
   9.3 This policy does not form part of an employee’s contract of employment and TDGP may amend it at
   any time so to improve its effectiveness at combatting bribery and corruption.