Bribery Act (2010) & Modern Slavery Act (2015)

Bribery Act (2010)

Anti-Bribery Policy of Air For Life UK Ltd

Introduction

Bribery is committed in the conduct of the company's business by the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust.

Bribery is a criminal offence under The Bribery Act 2010. This Company prohibits any form of bribery and we require the fullest possible compliance with our anti-bribery policy from everyone connected with our business at all times. All business must be completed with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by employees, sales representatives, distributors or by any third parties acting for or on behalf of Air For Life UK Ltd.

Offences

It is a criminal offence to:

  • offer a bribe;
  • accept a bribe;
  • bribe a foreign official;
  • as a commercial organisation, to fail to prevent a

You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. The Company could also face prosecution and be liable to pay an unlimited fine.

Purpose

The purpose of this policy is to convey to all employees and interested parties of Air For Life UK Ltd the rules of the Company in relation to our unequivocal stance towards the eradication of bribery and our commitment to ensuring that Air For Life UK Ltd conducts its business in a fair, professional and legal manner at all times.

Scope

This policy applies to all employees of Air For Life UK Ltd regardless of seniority or gender. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement and throughout our supply chain.

We will encourage the application of this policy where our business involves the use of third parties

e.g. suppliers, sales representatives, consultants, contractors and/or our distributors and their representatives, consultants, contractors or sub-distributors.

Policy

It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for the Company,  or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

It is also prohibited to act in the above manner, in order to influence an individual in his capacity as a public official or foreign public official. You should not make any payment to a third party on behalf of a public official or foreign public official under any circumstance.

If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact the Manager so that appropriate action can be taken as considered necessary by the Company. You may be asked to give a written account of events.

If you, as an employee or person working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this to your line manager or a company officer. You may be asked to give a written account of events.

Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.

The Company will ensure that all of its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately at all times.

Air For Life UK Ltd takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.

We will uphold all international and UK laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, an agency worker, contractor etc and may result in further action being taken through prosecuting authorities.

June 2020

Air For Life UK Ltd

 

Modern Slavery Act (2015)

Anti- Modern Slavery Policy

This statement constitutes Air For Life UK Ltd’s compliance with the statutory provisions of The Modern Slavery Act 2015.

Modern slavery is a violation of the human rights that every individual is entitled under international law and is also a crime both under international law and the law of the UK as set out in the Modern Slavery Act of 2015.

Modern slavery is a term that is used to describe slavery, forced labour and human trafficking and Air For Life UK Ltd has a zero tolerance policy towards any and all acts of modern slavery wherever this may occur in the world.

Air For Life UK Ltd will not undertake any business with any company that is connected with, or may be found to support any act(s) of modern slavery whether directly or indirectly. This Company is committed to ensuring that all supply chain companies associated with Air For Life products comply with this Company’s zero tolerance policy of any act of modern slavery or human trafficking at all times.

Our due diligence and supply chain policies regarding modern slavery are designed to ensure that all companies associated with our products are aware of this Company’s zero tolerance policy to modern slavery and to ensure that any company that we do business with also adopts the same zero tolerance approach to all forms of modern slavery and human trafficking, including within their own supply chains.

Air For Life UK Ltd fully supports UK and International law in eradicating modern slavery in all forms throughout the world.

June 2020

Air For Life UK Ltd