Anti-Bribery and Corruption Policy

Double values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. The honest actions and conduct of our staff as well as others acting on our behalf are key to maintaining these standards.

The purpose of this document is to set out our policy in relation to bribery and corruption. The policy applies strictly to all employees (whether temporary, fixed-term or permanent), agents, consultants, contractors and to any other people or bodies associated with Double, wherever they are based.

Understanding and recognising bribery and corruption

Acts of bribery or corruption are designed to influence an individual in the performance of their duty and incline them to act in a way that a reasonable person would consider to be dishonest under the circumstances.

Bribery can be defined as offering, promising, receiving or giving a financial (or other) advantage to another person so as to induce or influence an action or decision.

Corruption is any form of abuse of entrusted power for private gain and may include, but is not limited to, bribery.

Bribes are not always a matter of handing over or receiving cash. Gifts, hospitality and entertainment can be bribes if they are intended to influence a decision.

Facilitation payments and charitable contributions can also be deemed as bribes.

Penalties

Double is bound by the Bribery Act 2010 which came into force on 1st July 2011 and take our legal responsibilities seriously. Under that Act, bribery by individuals is punishable by up to 10 years imprisonment and/ or an unlimited fine. If Double is found to have taken part in bribery or is found to lack adequate procedures to prevent bribery, it too could face an unlimited fine.

A conviction for a bribery or corruption related offence would have severe reputational and/or financial consequences for Double.

Policy

Double will not tolerate bribery or corruption in any form.

We prohibit the offering, giving, solicitation or acceptance of any bribe or corrupt inducement, whether in cash or in any other form:

• To or from any person or company wherever located, whether a public official or public body, or a private person or company

• By any individual employee, partner, agent, consultant, contractor or other person or body acting on Double’s behalf

• In order to gain any commercial, contractual or regulatory advantage for the practice in any way which is unethical or to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual

This policy is not intended to prohibit the following practices provided they are appropriate, proportionate and are properly recorded:

• Normal hospitality

• Fast tracking a process which is available to all on the payment of a fee; and/or

• Providing resources to assist a person or body to make a decision more efficiently, provided that it is for this purpose only

It may not always be a simple matter to determine whether a possible course of action is appropriate. The below requirements give some guidance, but if you are in any doubt as to whether a possible act might be in breach of this policy or the law, the matter should be referred to a Company Director who will seek further advice.

• It is not made with the intention of influencing to obtain or reward the gain or retention of business.

• It is not made with the suggestion that a return favour is expected.

• It is in compliance with local law

• It is given in the name of the company not an individual.

• It does not include cash or a cash equivalent

• It is appropriate for the circumstances (e.g. small Christmas or thank you gifts)

• It is of an appropriate type and value and given at an appropriate time

• It is given/ received openly, not secretly

• It is not selectively given to a key, influential person

• It is not offered to or accepted from a government official or politician without prior approval from a Company Director.

The Company Directors will investigate thoroughly any actual or suspected breach of this policy. Employees found to be in breach of this policy may be subject to disciplinary action which may ultimately result in their dismissal for gross misconduct.

Key risk areas

Bribery can be a risk in many areas of the organisation. Below are the key areas you should be aware of in particular:

• Excessive gifts, entertainment and hospitality can be used to exert improper influence on decision makers. Gifts, entertainment and hospitality are acceptable provided they are within reasonable limits. Any excessive gifts or hospitality, either given or received, should be reported to a Company Director.

• Facilitation payments are used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer has an entitlement as of right. Double will not tolerate or excuse such payments being made.

• Reciprocal agreements or any other form of ‘quid pro quo’ are never acceptable unless they are legitimate business arrangements which are properly documented and approved by a Company Director. Improper payments to obtain new business, retain existing business or secure any improper advantage should never be accepted or made.

• Actions by third parties for which Double may be held responsible can include actions by a range of people, e.g. agents, contractors and consultants. Appropriate due diligence should be undertaken before a third party is engaged. Third parties should only be engaged where there is a clear business rationale for doing so, with an appropriate contract. Any payments to third parties should be properly authorised and recorded.

• Record keeping can be exploited to conceal bribes or corrupt practices. We must ensure that we have robust controls in place so that our records are accurate and transparent.

Cultural Variations

We recognise that the practice of giving and receiving business gifts varies between countries, regions, cultures and religions so definitions of what is acceptable and not acceptable will inevitably differ for each.

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/ culture who may take offence), the gift may be accepted so long as it is declared to a Company Director who will assess the circumstances.

Employee responsibility and how to raise a concern

The prevention, detection and reporting of bribery or corruption are the responsibility of all employees and they are required to avoid any activities that could lead to, or imply, a breach of this policy.

If you become aware or suspect that an activity or conduct which is proposed or has taken place is a bribe or corrupt, then you have a duty to report this to a Company Director without delay.

No one that refuses to accept or offer a bribe or that reports a concern relating to a potential act of bribery or corruption, will suffer any detrimental treatment as result of doing so and Double will ensure you are fully supported in line with our Whistleblowing policy, even if investigation finds that you were mistaken.

Last Updated: January 2020