Anti-Bribery Policy for Suppliers

One of our core values is to uphold responsible and fair business practices. We’re committed to promoting and maintaining the highest level of ethical standards in relation to all of our business activities. Our reputation for maintaining lawful business practices is of paramount importance and this policy is designed to preserve these values.

We have a zero tolerance policy towards bribery and corruption and are committed to acting fairly and with integrity in all of our business dealings and relationships. We also implement and enforce effective systems to counter bribery.

Purpose and Scope of Policy
This policy sets out the our position on any form of bribery and corruption and provides guidelines aimed at:

– Ensuring compliance with anti-bribery laws, rules and regulations; not just within the UK but in any other country where we may carry out business or where our business may be connected.

– Ensuring that any supplier, vendor, service provider or contractor to Richardson Milling ( UK) Ltd understands the risks associated with bribery, and to encourage them to follow our policies regarding these matters.

– Creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption.

Legal Obligations
The UK legislation on which this policy is based is the Bribery Act 2010 and it applies to the conduct of Richardson Milling ( UK) Ltd both in the UK and abroad. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is an offence in the UK to:

– Offer, promise or give a financial or other advantage to another person (i.e. bribe a person), whether within the UK or abroad, with the intention of inducing or rewarding improper conduct.

– Request, agree to receive, or accept a financial or other advantage (i.e. receive a bribe) for or in relation to improper conduct.

Policy Statement
We expect all our suppliers, contractors, vendors and service providers to:

– Comply with anti-bribery and anti-corruption legislation that applies in any jurisdiction in which they might be expected to conduct business with Richardson Milling ( UK) Ltd.

– Act honestly, responsibly and with integrity when dealing with Richardson Milling ( UK) Ltd.

– Help to safeguard and uphold the our core values by operating in an ethical, professional and lawful manner at all times.

Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside, or accounts created for the purposes of facilitating the payment or receipt of a bribe.

We recognise that industry practices may vary depending on a country and its culture. What is considered unacceptable in one place, may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this policy is expected of all our employees and therefore it is requested that all our suppliers, vendors, service suppliers and contractors help us to ensure no unlawful or unethical transactions or acts take place. If in doubt as to what might amount to bribery or what might constitute a breach of this policy please feel free to contact the Managing Director, Finance Director or Head of HR of Richardson Milling ( UK) Ltd The giving of business gifts from clients, customers, contractors and suppliers is not prohibited provided the following requirements are met:

– The gift is not made with the intention of influencing a staff member to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage.

– It complies with local law.

– It is given in the company’s name, not in the giver’s personal name.

– It does not include cash or a cash equivalent (such as gift vouchers).

– It is of an appropriate and reasonable type and value and given at an appropriate time.

– It is given openly, not secretly.

– It is approved in advance by a director of the Richardson Milling ( UK) Ltd

In summary, it is not acceptable 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, or to provide a payment, gift or hospitality to a specific Richardson Milling ( UK) Ltd staff member with the expectation that it will obtain a business advantage to your business. We ask our suppliers to study the rules we request all our staff to follow regarding gifts, hospitality and entertainment to avoid any embarrassing situations.

Responsibilities and Reporting Procedure
We encourage all employees, associated persons, suppliers, vendor service providers and contractors to be vigilant and to report any unlawful conduct, suspicions or concerns promptly and without undue delay, so that an investigation may proceed and any action can be taken expeditiously. In the event that you wish to report an instance or suspected instance of a request to make an undue payment or gift to a staff member (bribery) we request you disclose that to the Managing Director, Finance Director or Head of HR of Richardson Milling ( UK) Ltd immediately.

Confidentiality will be maintained during the investigation to the extent that this is practical and appropriate in the circumstances. We are committed to taking appropriate action against bribery and corruption. This could include either reporting the matter to an appropriate external government department, regulatory agency, or the police and/or taking internal disciplinary action against relevant employees and/or terminating contracts with associated persons.

We will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that actual or potential bribery or corruption has taken place or may take place in the future.

Record Keeping
All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept off the record to facilitate or conceal improper payments.

Sanctions for Breach
A breach of any of the provisions of this policy will constitute a disciplinary offence and will be dealt with in accordance with our disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render an employee liable to summary dismissal.

As far as associated persons are concerned, a breach of this policy could lead to the suspension or termination of any relevant contract, sub-contract or other agreement.

Monitoring Compliance 

Our Managing Director, Finance Director and Head of HR all have responsibility for ensuring compliance with this policy and will review its contents on a regular basis. They will be responsible for monitoring its effectiveness and will provide regular reports in this regard to the directors of the company who have overall responsibility for ensuring this policy complies with the company’s legal and ethical obligations.

We will provide training to all employees to help them understand their duties and responsibilities under this policy. Our zero tolerance approach to bribery will also be communicated to all business partners at the outset of the business relationship with them and as appropriate thereafter.

Examples of Potential Risks
The following is a non-exhaustive list of possible issues which raise bribery concerns and which you should report in accordance with the reporting procedure set out above:

– A third party insists on receiving a commission or fee before committing to signing a contract with Richardson Milling (UK) Ltd , or carrying out a government function or process for Richardson Milling ( UK) Ltd

– A third party requests payment in cash, or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made.

– A third party requests an unexpected additional commission or fee to facilitate a service.

– A third party demands lavish, extraordinary or excessive gifts or hospitality before commencing or continuing contractual negotiations or provision of services.

– You are offered an unusually lavish, extraordinary or excessive gift or hospitality by a third party.

– You receive an invoice from a third party that appears to be non-standard or extraordinary.

– Richardson Milling ( UK) Ltd is invoiced for a commission or fee payment that appears large given the service stated to have been provided.