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Anti Bribery Policy

Policy Statement

HNH Partners Limited is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on HNH Partners Limited ‘s behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.

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 and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.

HNH Partners Limited requires all those who are associated with it to observe the highest standards of impartiality, integrity and objectivity.

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 in the UK and abroad.

Who is covered by the policy?

This policy applies to all individuals working at all levels and grades, including directors, senior managers, officers, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located.

In this policy, third party means any individual or organisation that comes into contact with 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.

What are bribery and corruption?

Corruption is the misuse of office or power for private gain.
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

What is not acceptable?

We do not (nor do we procure someone) to:

  • 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;

  • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure;

  • accept payment from a third party that we know or suspect is offered with the expectation that it will obtain a business advantage for them;

  • accept a gift or hospitality from a third party if we know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

  • threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

  • engage in any activity that might lead to a breach of this policy.

Gifts and hospitality

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from third parties unless otherwise specifically stated. However, any gift or hospitality:

  • must not be made with the intention of improperly influencing a third party or staff member 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 or benefits;

  • must comply with local law in all relevant countries;

  • must be given in the name of the organisation, not in an individual’s name;

  • must not include cash or a cash equivalent;

  • must be appropriate in the circumstances;

  • must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift;

  • must be given openly, not secretly.

Gifts must not be offered to, or accepted from, government officials or representatives, politicians or political parties, without the prior approval of the Compliance Officer.

We appreciate that the market 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 or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

Facilitation payments and kickbacks

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

Kickbacks are typically payments made in return for a business favour or advantage. We avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

Donations

We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices.

Monitoring and review

We will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness.