Policy Statement

AVR Group Ltd, conducts its business ethically, with emphasis on high standards of honesty and integrity.

We understand that bribery has adverse impact on firms, government & society. We therefore have zero tolerance to the making or receiving of bribes or corrupt payments, in any form. Such conduct is prohibited and this applies to both employees and anyone else acting on behalf of the business.

AVR Group is committed to compliance with the Bribery Act 2010 and all applicable legislation.

This Policy sets out our approach to ensuring that no bribes or corrupt payments are made, offered, sought or obtained by anyone acting on our behalf.

Scope

This Policy applies to all employees of AVR Group Ltd at all levels within the business. It also applies to anyone else acting on behalf of AVR Group.

Our Policy is published widely to employees, who are also trained thoroughly in its application. This training commences at induction for new employees on joining the business, with periodic refresher training also taking place – at least annually.

Our sub-contractors, advisers & consultants (& anyone else acting for the business) are also made aware of the Policy as part of our procurement process and must comply fully with the Policy.

All employees are responsible for prevention, detection and reporting of any form of bribery. Appropriate reporting channels are in place (including our dedicated Whistleblowing Policy) and also for people/organisations acting on our behalf – any suspicion of bribery must be reported promptly to a Director and will be handled confidentially.

AVR Group treats all matters of malpractice, improper action or wrongdoing seriously. We strongly encourage all our Policy touches upon to raise incidents or behaviours that are not in accordance with the Policy through the confidential channels detailed in this document.

Policy Objectives

AVR Group is committed to the following policy objectives:

• Maintaining ethical approaches to our business – our people will operate with honesty and integrity & in accordance with AVR Group’s Code of Professional Conduct.

• Promotion of a culture under which any act of bribery might take place is not acceptable.

• Zero tolerance of the making or receiving of bribes or corrupt payments, in any form.

• Protecting our reputation in the market by ensuring this Policy is comprehensively understood and applied at all levels of the business.

• Compliance with the Bribery Act 2010 and all other applicable legislation.

Definition

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Acts of bribery or corruption influence the individual in the performance of their duty and incline them to act dishonestly.

Under the Bribery Act 2010, it is an offence to:

• Offer a bribe.

• Receive a bribe.

• Bribe a Foreign Official.

• Consent or connive to the commission of a bribery offence by anyone associated with AVR Group in respect of business carried out on its behalf.

Such an offence can result in a fine and/ or up to a maximum of 10 years imprisonment.

Policy Implementation

In implementing this Policy, we will:

• Undertake risk assessment of exposure to bribery across all areas of the business.

• Review findings of the risk assessment at senior management & Board level, promptly undertaking any necessary action to reduce risk of bribery occurring.

• Conduct due diligence checks prior to appointment of third parties carrying out work on behalf of the business.

• Where risk of bribery associated with appointment of third parties is categorised as ‘medium’ or ‘high’, we will undertake extensive checks to satisfy ourselves that the person can be trusted not to use bribery on our behalf.

• Monitor hospitality, promotional & entertainment activity & expenditure via regular review of a Register of Gifts, Hospitality & Entertainment.

• Ensure that all staff complete the above Register promptly & thoroughly.

• Train all staff thoroughly in compliance and how to report suspected bribery, with regular refresher training taking place.

• Encourage staff & third parties carrying out work on our behalf to report suspected bribery to a Director at the earliest stage possible.

• Provide confidential reporting channels to a Director of the business.

• Issue a copy of the Policy to all staff & existing sub-contractors/ business partners.

• Integrate the Policy into the AVR Group Employee Handbook.

• Promptly and thoroughly investigate any cases of suspected fraud/bribery, reporting any case of fraud/bribery to the Authorities immediately.

• Consider taking disciplinary action against anyone who fails to comply with the Policy up to and including dismissal.

Political and charitable contributions

AVR Group does not make contributions or donations to political organisations or to political candidates – whether individually or collectively.

We do, however, reserve the right to make donations to charitable organisations as part of our approach to corporate social responsibility. However, these must not and will not be used to exert improper influence. All charitable donations must be authorised by the Managing Director.

Facilitation payments

Facilitation payments, which are payments to induce officials to perform routine functions they are otherwise obliged to perform, are bribes. These payments are not allowed and breach the Bribery Act.

Legally required administrative fees or those in relation to genuine fast-track services are allowed and are not considered facilitation payments. All such payments must be authorised in advance by a Director.

Gifts, hospitality & entertainment

Genuine expenditure in respect of gifts, hospitality & entertainment which is bona fide, reasonable and proportionate may be made and does not breach the Bribery Act. All such expenditure must be recorded in the Register of Gifts, Hospitality & Entertainment and will be regularly audited by AVR Group’s Financial Director on behalf of the business. The latter will also conduct spot checks to ensure that the Register is being correctly completed and that expenditure is reasonable & proportionate.

Gifts, hospitality & entertainment must only be provided to cement good relationships. They must never be provided to exert undue influence on the recipient - whose independence must not be affected. All such expenditure must comply with AVR Group’s Code of Professional Conduct.

Policy Review

AVR Group will review and update (where latter necessary) this Policy periodically and at least annually, ensuring continued compliance and that all policy approaches remain suitable and proportionate to risks faced.

Responsibility and Authorisation

Our Managing Director carries responsibility for anti-bribery within the business, provides top level commitment and has signed this Policy as such.