The policy, therefore, has the full and unequivocal support and commitment from the Directors, the management team and the Parente family. We will uphold all laws relevant to countering bribery and corruption. However, we remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

About this policy
The purpose of this policy is to:
1) set out our responsibilities, and of those working for us, in observing and upholding our position on
bribery and corruption; and
2) provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years imprisonment and/or a fine. As an employer, if we fail to prevent bribery, we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We, therefore, take our legal responsibilities very seriously.

The Company will ensure that briefing on this policy, and our associated whistle-blowing policy, will form part of
the induction process for all new workers. Existing workers should ask their Department Manager if they are unsure of how to implement and adhere to this policy.

We have identified the following as particular risks for our business:
1) third parties engaging in, or being accused of engaging in, improper business practices which impact
Welbeck’s business.
2) third parties paying bribes, or requiring that bribes are paid to them.
3) third parties insisting on receiving a commission or fee payment before committing to sign up to a
contract with us or facilitate a service.
4) third parties asking for payment in cash and/or refusing to sign a formal commission or fee agreement,
or to provide an invoice or receipt for a payment made.
5) third parties asking for a payment to be made to a country or geographic location different from where
the third-party resides or conducts business.
6) third parties asking for a payment to be made to "overlook" potential legal violations.
7) third parties requiring you to provide employment or some other advantage to a friend or relative.
8) receiving an invoice from a third-party that appears to be non-standard, customised, or large given the
service provided.
9) being offered an unusually generous gift or lavish hospitality by a third-party.

To address those risks, we have taken the following steps:
1) Regular monitoring and reporting on employee expense claims and requests for payments to third
parties, by the Finance Department.
2) Compliance with an invoice authorisation procedure where all invoices are approved by a Department
Manager and reviewed by a member of the Finance Department. Invoices of a high value require
approval by the Financial Controller or Chief Executive.
3) Publication of this policy and the whistle-blowing policy to all staff and briefing to new starters as part
of the company’s induction.
4) Anti-Bribery training provided to specific key members of staff.
5) Distribution of this policy statement to all suppliers, contractors, consultants, agents, and tenants.

In this policy, third-party means any individual or organisation you encounter during the course of your work for us and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians, and political parties.

This policy does not form part of any employee's contract of employment, and we may amend it at any time.

Who must comply with this policy?
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, sponsors, or any other person associated with us, wherever located.

What are bribery and corruption?
A bribe is defined in law as an inducement or reward that is offered, promised, or provided in order to gain a commercial, contractual, regulatory, or personal advantage. The Bribery Act 2010 lists four main offences:
1) Giving a bribe.
2) Receiving a bribe.
3) Bribing a foreign public official.
4) The corporate offence of failing to prevent bribery by an associated person for the Company’s benefit.

It is not acceptable for the Company (or for someone acting on its behalf) or for you as an individual to:
1) Give, promise to give, or offer a payment, gift or hospitality with the expectation or hope that a
business advantage will be received or to reward a business advantage already given; or
2) Give, promise to give or to offer a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine or procedure; or
3) Accept payment from a third-party that you know (or suspect) has been offered with the expectation
that it will obtain a business advantage for them; or
4) Accept a gift or hospitality from a third-party if you know (or suspect) that it has been offered or provided with an expectation that a business advantage will be provided by us in return; or
5) Threaten or retaliate against another worker who has refused to commit a bribery offence or who has
raised concerns under this policy or the Company’s whistle-blowing policy; or
6) Engage in any activity that may lead to a breach of this policy.

Corruption is the abuse of entrusted power or position for private gain.
Examples: Offering a bribe: You offer a potential client ticket to a major sporting event, but only if they agree to do business with us. This would be an offence as you are making the offer to gain a commercial and contractual advantage. We may also be found to have committed an offence because the offer has been made to obtain business for us. It may also be an offence for the potential client to accept your offer.

Receiving a bribe:

A supplier gives your nephew a job but makes it clear that in return, they expect you to use your influence in our organisation to ensure we continue to do business with them.

It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.
Bribing a foreign official: You arrange for the business to pay an additional "facilitation" payment to a foreign official to speed up an administrative process such as clearing our goods through customs.

The offence of bribing a foreign public official is committed as soon as the offer is made. This is because it is made to gain a business advantage for us. We may also be found to have committed an offence.

What you must not do:
It is not acceptable for you (or someone on your behalf) to:
1) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or reward a business advantage already given.
2) give or accept a gift or hospitality during any commercial negotiations or tender process if this could be perceived as intended or likely to influence the outcome.
3) accept a payment, gift or hospitality from a third-party that you know, or suspect is offered with the expectation that we will provide a business advantage for them or anyone else in return.
4) accept hospitality from a third-party that is unduly lavish or extravagant under the circumstances.
5) offer or accept a gift to or from government officials or representatives, politicians, or political parties without the prior approval of your manager.
6) threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; or
7) engage in any other activity that might lead to a breach of this policy.

Gifts and corporate hospitality 
The provision of gifts and corporate hospitality is a relatively common business practice, and it is not in itself unlawful. However, gifts, hospitality and political or charitable donations will be regarded as bribes if they are given or received with the intention of influencing business decisions.
This policy does not, therefore, prohibit normal and appropriate hospitality (given and received) to or from third parties. The giving and receiving of gifts are not prohibited if the following conditions are met:
1) It 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, or in explicit or implicit exchange for favours and benefits.
2) It complies with local law.
3) It is appropriate in the circumstances, and considering the reason for the gift, it is of an appropriate type and value and is given at an appropriate time. An example here would be a small gift given to a supplier or contractor at Christmas.
4) It is given in the Company’s name and not in your name.
5) It is given openly, not secretly; and
6) It does not include cash or a cash equivalent (such as gift certificates or vouchers); and
7) No gift should be offered to, or accepted from, government officials or representatives or from politicians or political parties without the express prior approval of your line manager. Promotional gifts of low value such as branded stationery to or from existing customers, supplies and business partners will usually be acceptable. Reimbursing a-third party’s expenses or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not normally amount to bribery. However, a payment more than genuine
and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable.
We appreciate that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. The intention behind it should always be considered.

Facilitation payments and kickbacks
A facilitation payment is typically a small, unofficial “grease” payment made to a government official, for example, a customs officer or immigration official, to ensure that they perform their duty either more promptly or at all. A kickback payment is typically a payment made in return for a business favour or advantage; for example, a contractor or supplier may pay a kickback to another contractor or supplier who introduces and/or recommends them to one of their customers or clients. Kickback payments have been commonplace until recently and would previously have been regarded as an “above board” and legitimate business practice. For the avoidance of any doubt, the Company does not make, and will not accept, facilitation payments or kickbacks of any kind.

If you are asked to make a payment on the Company’s behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided.
You should always ask for a receipt which details the reason for the payment and if you have any suspicions, concerns, or queries regarding a payment you should raise them immediately with the Financial Controller or Chief Executive Officer (or, in the case of the School of Artisan Food, the School’s Director).
You must avoid engaging in any activity that might lead to, or suggest, that a facilitation or kickback payment will be accepted by the Company.

Donations
From time to time the Company will make charitable donations, ensuring first that they are legal and ethical.
We may also, on occasion, host or participate in corporate entertainment or charity events; please note that in these circumstances no-one other than the Financial Controller or, in their absence, the Chief Executive Officer (or, in the case of the School of Artisan Food, the School’s Director) may authorise a charitable donation,
including the donation of items or monies to be offered as a prize, or the sponsorship of an external event.

Record keeping (including expense claims)
The Company has implemented appropriate internal controls and will keep detailed financial records which will evidence the business reason for any payments made to a third-party.
You must ensure that all expense claims relating to hospitality, gifts or expenses incurred in connection with third parties are submitted in accordance with the Company’s expense policy and specifically, the expense claim should record the reason for the expenditure.
All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or
conceal improper payments.

Your responsibilities
As regards your individual responsibilities you must ensure that you read, understand, and comply with this policy at all times.
We regard the prevention, detection and reporting of bribery and other forms of corruption as being a shared responsibility between the Company and all of those working for us, or under our control. You are therefore also required to avoid any activity that might lead to, or suggest, a breach of this policy.

If you believe or suspect that action has been taken, or may be taken, that breaches or conflicts with this policy, it is your responsibility to notify your manager or a more senior manager. For example, if a supplier or tenant (or a potential supplier or tenant) offers you something to gain an advantage with us, you should report it immediately to the Financial Controller or Chief Executive Officer (or, in the case of the School of Artisan Food, the School’s Director). Suppliers include businesses that provide items such as IT equipment, stationery, and utilities, together with services such as legal and HR advice, training, recruitment advertising and the supply of agency staff.

Raising a concern
The Company recognises that if this policy is to be effective, employees and workers should have the means to raise any concerns and to report actual or suspected violations at the earliest opportunity and via a means where they can do so in confidence and without risk of reprisal.

We ask therefore that you raise any concerns you may have about any issue or suspicion of malpractice at the earliest possible stage. If you fail to report your suspicions you may become implicated in the wrongdoing, which will be regarded as a serious matter. We do expect therefore that if you have a serious concern(s), you will come forward and voice that concern as soon as possible using the procedure set out in the Company’s whistle-blowing policy.

If you are unsure about whether a particular act, or suspected act, constitutes bribery or corruption, or if you have any other queries, you should raise them with your line manager or with the Financial Controller or Chief Executive Officer (or, in the case of the School of Artisan Food, the School’s Director).

It is important that you tell your Head of Department or the Financial Controller or Chief Executive Officer (or, in the case of the School of Artisan Food, the School’s Director) as soon as possible if:
1) You are offered a bribe by a third-party, for example, a supplier or tenant; or
2) You are asked to make an unusual payment to a third-party; or
3) You suspect that either of the above may happen in the future.
4) You should also report it straightaway if you believe that you are a victim of another form of unlawful activity.

Protection
We recognise that workers who refuse to accept an offer or a bribe, or those who raise concerns or report another’s wrongdoing, may be worried about possible repercussions. The Company is wholly committed to offering long-term and ongoing support to anyone who raises genuine concerns in good faith under this policy
and to ensure that no-one suffers any detrimental treatment resulting from a refusal to take part in bribery or corruption. “Detrimental treatment” includes dismissal, disciplinary action, threats, or other unfavourable treatment such as being purposely excluded from meetings, conversations, and events that under normal circumstances you would expect to participate in. If you have a genuine belief in the authenticity of the information being disclosed and you are acting in good faith rather than for personal gain, you will be fully protected, both in law and by the Company’s whistle-blowing policy even if it is later found that you were mistaken. Please note however that this protection does not apply to someone who maliciously raises a concern that they know is untrue. Malicious allegations of this nature will be regarded as a serious disciplinary matter.

If you believe that you are suffering from any form of retribution (including harassment, intimidation, and victimisation) or if you are being treated less favourably in any way as a result of having raised your concerns you should speak with the Financial Controller or Chief Executive Officer straightaway (or, in the case of the School of Artisan Food, the School’s Director). You also have the right to raise a grievance in accordance with the Company’s grievance procedure.

Breaches of this policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct. Any worker, including for example a contractor, consultant, freelance agent, supplier, or franchise partner who is found to have breached this policy will normally have his/her contract with the Company (including any informal arrangement for the supply of goods and services) terminated with immediate effect. Furthermore, an individual who is found to have committed an act of bribery and/or corruption will face up to ten year’s imprisonment and, if the Company is found to have taken part in the act of bribery and/or corruption – or has failed to take reasonable steps to prevent it – we could face an unlimited fine, adverse publicity and potential damage to our reputation. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Potential risk scenarios: "red flags"
The following is a list of possible red flags that may arise during your time working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
If you encounter any of these red flags while working for us, you must report them promptly to your manager or the Financial Controller or Chief Executive Officer using the procedure set out in the whistleblowing policy:
1) you become aware that a third-party engages in, or has been accused of engaging in, improper business practices.
2) you learn that a third-party has a reputation for paying bribes, or requiring that bribes are paid to them,
or has a reputation for having a "special relationship" with foreign government officials.
3) a third-party insists on receiving a commission or fee payment before committing to sign up to a contract
with us or carrying out a government function or process for us.
4) a third-party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or
to provide an invoice or receipt for a payment made.
5) a third-party request that payment is made to a country or geographic location different from where the
third-party resides or conducts business.
6) a third-party request an unexpected additional fee or commission to "facilitate" a service.
7) a third-party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services.
8) a third-party request that a payment is made to "overlook" potential legal violations.
9) a third-party request that you provide employment or some other advantage to a friend or relative.
10) you receive an invoice from a third-party that appears to be non-standard or customised.
11) a third-party insists on the use of side letters or refuses to put terms agreed in writing.
12) you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided.
13) a third-party request or requires the use of an agent, intermediary, consultant, distributor, or supplier that is not typically used by or known to us.
14) you are offered an unusually generous gift or offered lavish hospitality by a third-party.