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Bribery Policy

Ethics & Bribery Act

This statement is made in regard to our business ethics and pursuant to The Bribery Act 2010.

Bribery in the context of this document is defined as “an offer or receipt of any gift, fee, reward or other advantage to or from any person as an inducement to do something in the conduct of Peppers business, which is dishonest, illegal or a breach of trust’.”

We believe that being a responsible and ethical business partner, employer, customer and supplier is not just a reaction to the challenges of legal compliance, but an important means of doing business and provides a clear market differentiator for the business, particularly in many developing regions.

The business ethics policy clearly defines what we consider to be acceptable and unacceptable business practices. We demand compliance with this policy from all employees.

The business will conduct its operations ethically and we operate a zero tolerance approach to the making or receiving of bribes or corrupt payments, in any form. This type of conduct is absolutely prohibited whether committed by employees or anyone else acting on the Company’s behalf.

In order to ensure that all understands their obligations in relation to this policy, we carry out the following:

  • Regular review of the business ethics policy, incorporating evolving standards and legislation and evaluating any risk to the businesses ethical standards.
  • Distributing the policy and ensuring its implementation.
  • Ensuring that all employees are aware of their obligations under the ethics code, through various communications channels, including values and induction training, employee magazines, awards programmes etc.
  • Providing specific training to all managers and supervisors on business ethics and preventing bribery and corruption through a tailored programme available in a variety of languages and formats.
  • Reinforcing our values and the importance of ethical behavior through induction, employment contracts, staff
    handbooks, and training.

A breach of this Policy by an employee or business partner could result in the Company breaching the Act. An offence under the Act can result in the business being fined and would likely lead to negative publicity and serious damage to the reputation of the brand.

  • Making unofficial payments to officials in order to obtain any permission, permit or stamp particularly in connection with importing or exporting goods
  • Appointing any third party or supplier to act on behalf of the business who we have good reason to believe to have engaged in any corrupt or unlawful conduct including any offences under the Act
  • Paying any third party for the purposes of being a ‘fixer’ to open doors and make connections for the business overseas.