Anti-Bribery Policy

1. Purpose and Scope This Anti-Bribery Policy outlines The Fenway Group Limited’s (“Fenway®”, “We”, “Us”, “The Company”) commitment to ethical business practices and compliance with the UK Bribery Act 2010. It applies to all employees, officers, directors, agents, consultants, contractors, suppliers and any other party acting on behalf of, or in collaboration with, the company. The purpose of this policy is to ensure that all business activities are conducted lawfully, with integrity and free from bribery and corruption.

2. Policy Statement Fenway® strictly prohibits all forms of bribery and corruption.

The company has zero tolerance for:

  • Offering, giving, soliciting or accepting bribes in any form.

  • Facilitating payments intended to secure routine government actions.

  • Indirect bribery through third parties.

3. Definitions

  • Bribe: a bribe is any offer, promise, gift or payment made to influence a person to perform their duties improperly.

  • Facilitation Payments: small, unofficial payments made to expedite routine government actions.

  • Third Parties: any individual or entity acting on behalf of the company, such as, though not limited to, agents, consultants or contractors.

4. Responsibilities

  • Employees: all employees are required to uphold the highest standards of integrity and comply with this policy. Employees must report any suspected or actual incidents of bribery to their immediate line manager or to a company director.

  • Managers: managers must ensure their teams understand and adhere to this policy and foster a culture of compliance.

  • Third Parties: All third parties acting on behalf of Fenway® must comply with this policy and will be subject to due diligence.

5. Gifts and Hospitality Fenway® acknowledges that gifts and hospitality can play a legitimate role in building business relationships.

However:

  • Gifts or hospitality must be reasonable, proportionate and transparent.

  • No gifts or hospitality should be given or received if they could be perceived as influencing business decisions.

  • Employees must seek approval from their immediate line manager or to a company director before offering or accepting any gifts or hospitality above £10.00 (ten pounds GBP).

6. Facilitation Payments Facilitation payments are prohibited. If an employee is faced with a request for a facilitation payment, they must refuse and report the incident to their immediate line manager or to a company director.

7. Charitable Donations and Sponsorships Any charitable donations or sponsorships made on behalf of the company must:

  • Comply with applicable laws and regulations.

  • Be transparent and properly documented.

  • Not be used as a cover for bribery or other corrupt practices.

8. Due Diligence The company may conduct due diligence at any time on third parties to ensure compliance with this policy. This may include reviewing their policies, reputation and past conduct.

9. Reporting Concerns Any employee or third party who suspects or becomes aware of a breach of this policy must report it immediately to their immediate line manager or to a company director. Reports will be treated confidentially and the company will protect whistle-blowers from retaliation.

10. Training Fenway® will provide training to employees and relevant third parties to ensure understanding and compliance with this policy.

11. Consequences of Non-Compliance Non-compliance with this policy may result in disciplinary action, including dismissal and may also lead to civil or criminal prosecution. Third parties who breach this policy may have their contracts terminated.

12. Monitoring and Review The company will regularly monitor the effectiveness of this policy and review it annually to ensure its continued relevance and compliance with the law.

13. Approval and Ownership This policy is approved by the managing director of Fenway® and is owned by the managing director of Fenway®. All questions or concerns about the policy should be directed to managing director of Fenway® via admin@fenway.uk.

This policy was created and published by Fenway®, being The Fenway Group Limited of Prospect House, Lonsdale Gardens, Tunbridge Wells, TN1 1NU, and was last reviewed and updated 10th January 2025. This is version 1.0. This policy will be reviewed periodically and may be changed without notice. For further information please contact us via admin@fenway.uk. Document reference: FENDOC.00007-1.0.