Anti-Bribery Policy

1. Purpose

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the company’s (LBR UK Holdco Limited and subsidiaries) business is conducted in a socially responsible manner.

2. Policy statement

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, by implementing and enforcing effective systems to counter bribery.

Law Business Research (‘LBR’ or ‘we’ or ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad, including the Prevention of Bribery Ordinance (Hong Kong).

Bribery and corruption are punishable for individuals by up to 10 years’ imprisonment and a fine in the UK. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face massive reputational damage. We therefore take our responsibilities very seriously.

3. Scope

3.1 Who is covered by the policy?

In this policy, ‘third party’ means any individual or organisation with which you come into contact during the course of your work for us, including actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers and government and public bodies, including their advisers, representatives and officials, politicians and political parties. This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors and any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as ‘employees’ in this policy).

This policy covers:

  • bribes;
  • gifts;
  • facilitation payments;
  • political contributions; and
  • charitable contributions.

3.2 Bribes

Employees must not engage in any form of bribery, either directly or through any third party (eg, an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world.

3.3 Gifts

  • Employees must not offer or give any gift:
  • which could be regarded as illegal or improper, or which violates the recipient’s policies;
  • to any public employee or government officials or representatives, or politicians or political parties; or
  • which exceeds £100 in value for each individual gift or exceeds £200 in total value in any financial year), unless approved in writing by the CFO or CEO.
  • Employees may not accept any gift from our business partners if:
  • it exceeds £100 in value for each individual gift or exceeds £200 in total value in any financial year), unless approved in writing by the CFO;
  • it is in cash (any amount); or
  • there is any suggestion that a return favour will be expected or implied.

If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided that it is then declared to the CFO and donated to charity. We appreciate that the practice of giving business gifts 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 is reasonable and justifiable. The intention behind the gift should always be considered.

3.4 Facilitation payments and kickbacks

Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low-level officials to obtain a level of service to which one would normally be entitled.

Our strict policy is that facilitation payments must not be paid. We recognise, however, that our employees may be faced with situations where there is a risk to the personal security of an employee or his/her family and where a facilitation payment is unavoidable, in which case the following steps must be taken:

  • Keep any amount to the minimum;
  • Create a record concerning the payment; and
  • Report it to the CFO

In order to achieve our aim of making no facilitation payments, any payments must be reported to the CFO, in order to evaluate the business risk and to develop a strategy to minimise such payments in the future.

3.5 Political contributions

We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this could be perceived as an attempt to gain an improper business advantage.

3.6 Charitable contributions

Charitable support and donations are acceptable, whether of in-kind services, knowledge, time or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices. No donation may be offered or made without the prior approval of the CEO.

All charitable contributions should be disclosed.

4. Your responsibilities

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify the CFO or the CEO if you believe or suspect that a conflict with or breach of this policy has occurred or may occur in the future.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationships with other workers if they breach this policy.

5. Record keeping

We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

You must declare gifts accepted or offered, which will be subject to managerial review.

You must ensure that all expenses claims relating to gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts may be kept ‘off-book’ to facilitate or conceal improper payments.

6. How to raise concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with the CFO.

7. What to do if you are a victim of bribery or corruption

It is important that you tell the CFO as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future or believe that you are a victim of another form of unlawful activity.

8. Protection

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

We are committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that actual or potential bribery or another corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the CFO immediately. If the matter is not remedied and you are an employee, you should raise it formally using the company’s grievance procedure.

9. Communication

The policy will be communicated to all employees and made available with other policies as part of the company handbook. All new employees will be informed about the policy as part of their induction and asked to formally accept the policy.

Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

10. Who is responsible for the policy?

The board of directors has overall responsibility for ensuring that this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The CFO has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring that those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.

11. Monitoring and review

The CFO will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

All employees are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing.

Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the CFO.

This policy does not form part of any employee’s contract of employment and may be amended at any time.

Tosh Bruce-Morgan
CFO Law Business Research Limited

21 August 2019

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