Anti-Bribery Policy

Policy Statement

Introduction – The Hoist People Ltd values its reputation for ethical behaviour, financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:

• setting out a clear anti-bribery policy
• establishing and implementing anti-bribery procedures as appropriate
• communicating this policy and any relevant procedures to employees and to others who will perform services for the Company
• undertaking appropriate due diligence measures before engaging others to represent the Company in their business dealings
• monitoring and reviewing risks and effectiveness of any anti-bribery procedures that are in place
• prohibiting offering, giving, solicitation or acceptance of any bribe (whether cash or other inducement).

This policy prohibits any inducement that results in a personal gain or advantage to the recipient, or any person or body associated with them, and which is intended to influence them to take action that may not be solely in the interests of the Company or of the person or body employing them or whom they represent.

This policy is not meant to prohibit normal and appropriate hospitality or the giving of a gift on a festival or at another special time, providing they are customary, proportionate and properly recorded.

Inevitably, decisions as to what is acceptable may not always be easy. If employees are in any doubt as to whether a potential act constitutes bribery, the matter should be referred to a director before proceeding.

Employee responsibility – Prevention, detection and reporting of bribery is the responsibility of all employees, and the Company is committed to:

• encouraging employees to be vigilant and report any suspicion of bribery
• providing employees with suitable channels of communication and ensuring that sensitive information is treated appropriately
• investigating instances of alleged bribery and assisting the Police and other appropriate authorities in any resultant prosecution
• taking disciplinary action against any individual(s) involved in bribery.

Any suspicion of bribery should be reported in confidence to the Managing Director, who has the overall responsibility for bribery prevention.

Ben Hewison
Managing Director

February 2024