Hourigan Planning Limited Privacy Policy

This privacy policy sets out how Hourigan Planning Limited uses and protects any information that you provide to Hourigan Planning Limited. We may collect the information when you:

Use this website.
Respond to a consultation event.
Engage with a member of our team.
Engage with us via electronic communications.
Contact us by telephone.

Hourigan Planning Limited is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified then you can be assured that it will only be used in accordance with this privacy statement.

Hourigan Planning Limited may change this policy from time to time by updating this page. You should check this page occasionally to ensure that you are happy with any changes. This policy is effective from 1 April 2022.

What Information Do We Collect?

We may collect the following information:

Name and job title or profession.
Contact information including postal and email address and telephone number.
Demographic information such as postcode, preferences and interests.
Other information relevant to the services we offer.

The lawful basis for the collection and processing of your personal data is:

Contract – you may have engaged Hourigan Planning Limited to provide a product or service on your behalf.
Legitimate interest.
Consent – for direct marketing purposes.

What We Do With The Information We Gather?

We require information to understand your needs and provide you with a better service, and in particular for the following reasons:

Internal record keeping.
We may use the information to improve our products and services.
We may periodically send promotional communications about new products, special offers or other information which we think you may find interesting. This might be via email, direct mail or telephone.

From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, or mail. We may use the information to customise our website according to your interests.

Hourigan Planning Limited intends to keep data collected for anything up to seven years in order to maintain contact with you. We justify this time period as we believe that in this time your circumstances may change in which you may require our services.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How We Use Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our website.

Links To Other Web Sites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling Your Personal Information

You may choose to restrict the collection or use of your personal information in the following ways:

Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you want the information to be used for direct marketing purposes.
You can also indicate your marketing preferences at the point you sign your acceptance form as a client, if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at hello@houriganplanning.com or using the ‘unsubscribe’ button on any promotional emails we send to you.
You have the right to request the information we hold on you. If you would like to make a data access request, you can do this by writing to our office or emailing hello@houriganplanning.com
You also have the right to be forgotten and request that we delete your data from all our systems.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to hello@houriganplanning.com.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Your Acceptance of These Terms

By using our web site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our web site. Your continued use of our web site following the posting of changes to this policy will be deemed your acceptance of those changes

Labour Standards Policy

1. Introduction:

Hourigan Planning Limited recognises its obligation to provide our customers with high quality, professional goods and services at a competitive price whilst ensuring that at no point is any person in any part of the supply chain exploited or treated in a way that breaks relevant employment legislation. We are fully aware of the responsibilities we bear to all parties involved in each of the stages involved in producing our products and have such developed this policy to outline the standards that we, and ultimately all stakeholders involved with the business, should seek to adhere to Hourigan Planning Limited shall show a preference, where appropriate, to suppliers with higher labour standards.

2. Aims:

The aim of this policy is to promote understanding and awareness of employment laws and ethical standards. By detailing our labour standards to all parts of our supply chain we hope to develop better ethical standards by motivating our suppliers to adhere to it. It also describes the standard required of potential future suppliers.

3. Objectives:

The Hourigan Planning Limited Labour Standards objectives are as follows:

a. To become a progressive ethical company and comply with the ETI Base Code
b. KEY Suppliers, as denoted by our Quality Procedure, should have full compliance with the Ethical Trading Initiative (ETI) Base Code by December 2016
c. All suppliers should have compliance with at least 70% of the ETI Base Code, which must include the sections of the code that are deemed to be appropriate for Emergency Response as outlined in Section 3.10, by December 2015
d. All suppliers should fully comply with the ETI Base Code by August 2017
e. Encourage parties in our supply chain to develop their own labour standards system and provide help and support to allow them to do this

4. Policy Statement:

The Hourigan Planning Limited policy in relation to labour standards as relevant to the organisation itself, contractors, sub-contractors, suppliers and any other parties engaged through the supply chain is as follows:

a. We shall comply to all Employment Laws relevant to our business
b. We comply to the Health and Safety Act 1974 – as outlined by the Employee Handbook
c. We comply with all other Employment legislation – as outlined by the Employee Handbook
d. Our compliance with the above is kept up to date through regular reviews
e. We will work towards the ETI Base Code. This demonstrates compliance with the principles of the United Nations Global Compact, the UN Universal Declaration of Human Rights as well as the 1998 International Labour Organisation Declaration on Fundamental Principles and Rights at Work, in accordance with international, national and local law and practice
f. We shall encourage all suppliers and contractors to adhere to the Ethical Trading Initiative as part of their respective contracts

5. Management Representative:

The management representative assigned the responsibility of implementing an effective Labour Standards Assurance System (LSAS) is Marc Hourigan. The responsibilities of the Management Representative are as follows:

a. To develop procedures to meet policy requirements
b. To communicate labour standards issues to senior management
c. To liaise with companies in the supply chain to undertake labour standard status reviews
d. To set objectives and targets for labour standards assurance with plans for training, auditing and required action
e. To liaise with companies in the supply chain to implement a plan of action to meet objectives
f. To regularly review and improve the Labour Standards policy
g. To implement training for staff involved with the LSAS Hourigan Planning Limited LSAS Policy Document Revision Number: 0

6. Roles & Responsibilities:

Given the size of the company and the number of companies in the supply chain, it is adequate for Mr Hourigan to undertake the main responsibility of the LSAS. The Management Representative shall liaise with the management board to develop the LSAS and present any developments at regular intervals to the board. Members of staff involved with the LSAS shall be identified using the training records system and skills matrix. Target setting for staff involved with the LSAS shall be incorporated into the half-yearly and yearly personnel reviews as relevant Resources relating to the LSAS will be available to all involved staff via request.

7. Labour Standards Status Review:

Hourigan Planning Limited commit to undertaking a comprehensive Labour Standards Status Review; when contracting a new supplier and at regular routine visits to suppliers, to ensure that labour standards throughout our supply chain are satisfactory and continually improving. We recognise that if any contractor or sub-contractor were found to be using unethical or illegal labour programs, this would have a profound impact on the reputation and integrity of the company. The procedure for conducting a Labour Standards Review can be found in section 20 of the Quality Manual. The timescale of the Labour Standards Status Review is subject to change, given the findings from previous reviews, as deemed appropriate by senior management during a Quarterly Management Review.

8. Legal Requirements:

Hourigan Planning Limited commit to remain up to date with changes to relevant employment legislation through the use of due diligence and use of consultative professional support. Relevant employment legislation with regards to Hourigan Planning Limited direct operations is outlined in the Employee Handbook and is signed by all employees once read and understood.

9. Objectives, Targets & Programmes:

Hourigan Planning Limited commit to developing a Corrective Action Plan (CAP) as part of the Improvement Request form (IR) following each Labour Standards Status Review.The IR/CAP will be reviewed by senior management during the routine quality review, in line with the Quality Manual, to determine whether the company is on target to reach their objectives and to ensure these objectives are still appropriate. This will ensure that all relevant personnel will be kept up to date with the development of the LSAS programme.

10. Competence, Training & Awareness:

Hourigan Planning Limited commit to the training of relevant staff in order to be competent with handling the labour standards programme. Relevant staff for Hourigan Planning Limited are those involved in procurement new product development. Persons involved with the LSAS should:

a. Have a good understanding of how Hourigan Planning Limited operates with knowledge of the supply chain
b. Be in a position to contact suppliers and build a relationship with them
c. Be trained in the LSAS requirements
Training for the LSAS is implemented as part of Hourigan Planning Limited’s training checklist, which keeps a record of the training levels of all the staff at the company. Training reviews and development plans for the LSAS will be included as part of the current training system.

11. Communications:

Since the LSAS is embedded into the current Quality System, the existing training systems, quality systems and recorded communication will be used to address LSAS issues. We will use the IR system to log and monitor any adverse allegations, complaints or alerts relating to the LSAS.

12. Documentation & Records:

Documentation and records in relation to the LSAS shall be kept using standard document and record keeping procedures in line with other Quality Documents.

13. Operational Control:

For the direct operation of the company, the Employee Handbook documents the procedures involved with controlling the labour standards of the company and addressing any risks or breaches of this policy that may be posed. The senior management of Hourigan Planning Limited have identified two critical control points for labour standards in the supply chain; Supplier Approval and Supplier Visits.

14. Supply Chain Management:

Hourigan Planning Limited commit to monitoring and maintaining the labour standards in the company’s supply chain through the distribution and communication of the company’s labour standards policies along with the on going assessment of whether these standards are being met. This will occur using assessments at the control points. New suppliers must meet Hourigan Planning Limited’s initial approval that outlines the standards to which the supplier is expected to maintain as part of their contract. These standards comply fully with those required by the LSAS. Reviews shall be taken at routine visits to suppliers to ensure they continue to comply fully with the LSAS. The findings of supplier visits shall be noted in the routine quality review.

15. Emergency Response:

Hourigan Planning Limited have identified aspects of the ETI Base Code that are of particular importance for meeting minimum levels of labour standards. Sections 1.1, 1.2, 4.1 and 9.1 are regarded by Senior Management of GBUK as statements that justify emergency response. Emergency Response comprises a request for a written Corrective Action Plan within 14 days that is approved by all parties involved. Should this Corrective Action plan be deemed unacceptable then resourcing of production from within Hourigan Planning Limited’s existing supplier base shall be implemented within 30 days of the initial breach of the above minimum labour standards.

16. Performance Monitoring & Measurement:

Hourigan Planning Limited commit to monitoring the performance of the LSAS assessing the progress against the latest CAP where appropriate and setting relevant targets, in addition to those stipulated in this policy, to ensure the progression of the LSAS against our objectives. Progression of parties in the supply chain shall be measured against the level of compliance with the ETI Base Code.

17. Corrective Action:

The current IR quality system will be used to document improvements from labour standards audits.

18. Management Review:

Senior management will formally review the labour standards programme during the routine Management Review process.

19. ETI Base Code:

The ETI base Code can be found at:
http://www.ethicaltrade.org/sites/default/files/resources/ETI%20Base%20Code%2C%20English.pdf

Environmental & Sustainability Policy

Hourigan Planning Limited is committed to providing a safe and healthy workplace for its employees and aims to minimise its potential negative impact on the environment.

It operates in compliance with all relevant environmental legislation and strives to use environmental best practise in its day-to-day operations.

The Company:-

complies with its legal obligations under the current Health, Safety and Welfare Act and the Environmental Protection Act, together with other applicable statutory provisions and relevant codes of practice,
sets its own standards and targets if there are no relevant Government regulations,
fully integrates the consideration of environmental concerns and impacts into all of its decision making and activities,
promotes environmental awareness among all its employees, and fully encourages them to work in an environmentally responsible manner at all times,
trains, educates and informs its employees about environmental issues that may affect their day to day work,
reduces waste through re-use and recycling and by purchasing recycled, recyclable or re-furbished products and materials where these alternatives are available, economical and suitable,
promotes efficient use of materials and resources throughout its facility including water, electricity, raw materials and other resources, particularly those that are non-renewable,
purchases and uses environmentally responsible products accordingly,
encourages its employees to use public or share private transport to commute and to travel on work-related business, where transport systems allow efficient use,
communicates its environmental commitment to clients, customers and the public and encourage them to support it,
strives to continually improve its environmental performance and minimise the social impact and damage of activities by periodically reviewing its environmental policy in light of its current and planned future activities,
provides access to information on the company’s environmental performance to relevant interested parties, and
reviews its policy in line with its operations annually and makes necessary amendments as may be required.

Anti-Bribery Policy

As a company we are committed to preventing bribery. We have set out our policy statements in relation to the prevention of bribery below:

1. Introduction

As a UK-incorporated business Hourigan Planning Ltd is required to comply with UK anti-bribery legislation. Full details regarding the scope and application of the Bribery Act 2010 (“the Act”) is available in our ‘Anti-Bribery Guidance’ document.

No business can consider itself immune from the risk of being involved in an incident of bribery. We must therefore carefully consider the risk of bribery being committed by anyone working within or on behalf of our business, including third parties who provide services on our behalf. Once we have done this we must put appropriate measures in place to mitigate these risks.

These anti-bribery procedures explain the way in which we aim to fulfill these requirements and set out the processes which all staff must follow to ensure that our approach is effective. Our procedures are reviewed and updated regularly; please ensure that you are working from the current version.

Any breaches of these procedures will be dealt with severely and may be treated as gross misconduct.

2. Guidance on offences related to bribery

You have been provided separately with the ‘Anti-Bribery Guidance’ document which sets out the legislative and regulatory framework in this area. You must read this document carefully as it forms an important part of our bribery prevention policy.

3. Policy statements

As a company we are committed to preventing bribery. We have set out our policy statements in relation to the prevention of bribery below:

We will discharge our duties in relation to the prevention of bribery in the clearest possible way and to the highest possible standards.
We will remain aware of the risks associated with bribery and of the legal requirements imposed upon us.
We will establish and maintain appropriate risk-based policies.
The Board accepts ultimate responsibility for compliance with our anti-bribery policies and procedures and staff awareness of these policies and procedures and all staff have a day-to-day responsibility to act within the procedures.
We, or our agents acting on our behalf, will perform undertake reasonable and practicable due diligence on all [customers/suppliers] prior to establishing a relationshipengaging in business transactions with them and, where we find bribery to have taken place, will take the appropriate steps to safeguard Hourigan Planning Limited. This may mean declining to establish a relationship sales transaction with the [customers/suppliers] or requesting warranties to ensure that
Hourigan Planning Limited will not be implicated should the [customers/suppliers] subsequently face prosecution.
We will request that all of our [customers/suppliers] put ensure that adequate procedures are in place to safeguard themselves against the risk of bribery being committed by anyone providing services to them, and will ask them to confirm in writing that they have done this.
We will perform appropriate and proportionate due diligence on all members of staff both at take-on and on an on-going basis.
We will regularly communicate our strong anti-bribery stance to our staff and our [customers/suppliers].
We will conduct on-going monitoring of our anti-bribery policies and procedures to ensure that they remain appropriate and proportionate to our business.

4. Senior Management Engagement

The Board fully supports Hourigan Planning Ltd’s anti-bribery stance, and is actively involved in all key decisions in relation to our anti-bribery policies and procedures. It reviews and approves Hourigan Planning Ltd’s annual risk assessment, and is responsible for making any decisions based on the findings of that assessment.

The Board is also ultimately responsible for all communications relating to our anti-bribery policy, and for reviewing and signing off training in relation to the firm’s bribery prevention policies and procedures before this can be delivered to employees.

The Board delegates day-to-day responsibility for the management of Hourigan Planning Ltd bribery risks, including the signing off of training and communications and any business as usual bribery-related decisions to the Managing Director [responsible person].

5. Risk-based Approach to Bribery Prevention

The Ministry of Justice’s Guidance for firms on the application of the Bribery Act places an obligation on firms to adopt a risk-based, proportionate approach to the prevention of bribery.

In order for Hourigan Planning Ltd to be able to implement a risk-based approach to the prevention of bribery we have first conducted a risk assessment to assess the bribery risks within our business.

Details of our risk assessment process and other elements of our risk-based approach to bribery prevention are provided below.

5.1. Risk assessment process

Oversight of the effectiveness and implementation of our anti-bribery policies and procedures, including the operation of the risk-based approach, is the responsibility of the Managing Director under delegation from the Board. The Board decides upon our overall approach to the prevention of bribery in line with our business’s risk tolerance.

The environment and market in which we operate are constantly changing and evolving. To enable us to keep our bribery risk management processes up to date we should undertake a risk assessment and carefully monitor the environment and market in which we operate. Doing this ensures that we are aware of the degree of bribery risk associated with our business.

The Board has oversight of the Hourigan Planning Ltd risk assessment, and must ensure that an appropriate amount of resource is given to its completion. The risk assessment must identify internal and external sources of information which will assist us in categorising the bribery risks to our firm. Internal sources may include management information relating to employees’ completion of anti-bribery training or results of reviews of third party relationships. External sources may include guidance issued by a professional body such as the Ministry of Justice or results of reviewing anti-bribery procedures in place in partner firms.

Hourigan Planning Ltd has undertaken a bribery risk assessment taking in to account the following external factors:

The bribery risks presented by our relationships with our [customers/suppliers];
The jurisdictions in which our [customers/suppliers] operate;
The industries in which we operate and/or with which we have links;
The types of transactions we deal in;
The jurisdictions in which we operate;
Our use of advisors to assist us in conducting due diligence prior to establishing a relationship with a [customers/suppliers]; and
Any other bribery risks which we identify as possibly arising in the course of our usual business.

Hourigan Planning Ltd has also considered relevant internal factors, including:

The provision of staff anti-bribery training and testing of the effectiveness of that training;
Our remuneration policies, and whether they are likely to result in risk taking being rewarded;
The appropriateness of our corporate gifts and hospitality policy;
The appropriateness of any charitable donations which we make as an organisation;
The transparency and effectiveness of our financial controls;
The clarity of message received from senior management with regards to bribery prevention; and
Any other relevant internal factors which we may consider to have a bearing on our bribery risk profile.

Once completed, the risk assessment is accurately and appropriately documented, and is reviewed on an on-going basis in light of any changes within our business, for example if we begin to operate in a new, higher-risk industrial sector. Irrespective of this, our bribery risk assessment is reviewed and revised as appropriate at least annually.

A copy of our bribery risk assessment can be found as an attachment to these procedures.

5.2. Due Diligence

Hourigan Planning Ltd undertakes due diligence in respect of its associated persons (i.e. all persons providing a service to us) in order to assist in mitigating our bribery risks and complying with the Bribery Act. This due diligence forms part of our existing due diligence and anti-financial crime framework.

All of the due diligence that we undertake in relation to persons associated with us is carried out in accordance with our risk assessment and in light of the bribery risk that they pose to our business.

We will review and, where necessary, update our due diligence procedures in accordance with any updates made to the risk assessment.

Where due diligence enquiries have been unsatisfactory, refer all cases to The Managing Director. The Managing Director will document your enquiry and advise you on the best course of action to follow.

1. Gifts and Hospitality

The offering of gifts and hospitality is not something which the Bribery Act seeks to prohibit. However, the Bribery Act does require us to ensure that any gifts and hospitality offered or accepted by us are not intended to promote corrupt or inappropriate behaviour on the part of the receiver.

In order to minimise the risk that our gifts and hospitality arrangements might be used to bribe individuals or organisations we require that all gifts and hospitality with a value equal to or in excess of £100 be pre-approved by the Managing Director. The Managing Director will consider whether the gift or hospitality to be given or received is appropriate, and will record this along with his decision in Hourigan Planning Ltd Gifts Register. They will inform you by e-mail of their decision.

Any gifts or hospitality to be offered or received with a value below £100 do not require pre-approval from the Managing Director [responsible person] before they can be offered or accepted. Hourigan Planning Ltd has set the limit at £100 before pre-approval is required based on its existing guidelines and what it considers reasonable based on past expenditure.

Local managers review and sign off all expenses claims, whatever the amount to be claimed, before they are referred to the Managing Director for payment. Although there is no requirement for employees to report expenditure below £100 to the Managing Director directly, in heris capacity as Managing Director of Hourigan Planning Ltd, reviews all expenses claims prior to payment. The Managing Director will therefore become aware should any member of staff abuse the gifts and hospitality policy.

2. Charitable Donations

As an organisation we support the idea of charitable giving. It is therefore possible that Hourigan Planning Limited may, on occasion, give charitable donations. Should anyone wish Hourigan Planning Ltd to make a donation to a particular charity, they should refer their request to the CEO Managing Director and the Finance Commercial Director.

The CEO Managing Director and the Finance Commercial Director have ultimate responsibility for deciding whether and to whom charitable donations should be made. In considering whether to make a donation to a particular charity, the CEO Managing Director and the Finance Commercial Director will have regard to the possibility that the donation may be used as or perceived to be a bribe. They will agree and record donations to be made.

By ensuring that we refer all requests to make charitable donations in this manner we can ensure that we are giving money to legitimate organisations for legitimate reasons and avoid the misuse of company funds to commit acts of bribery.

3. Sponsorship

As an organisation we may from time to time sponsor events and seminars in conjunction with other firms.

The Board must approve any sponsorship which we undertake as an organisation. When approving sponsorship, they will take in to account the following factors:

The nature of the event;
The cost of the sponsorship;
The firm(s) with which we will be co-sponsoring the event; and
The firms to be invited to the event.

In considering the above factors, the Board will look to ensure that our sponsorship of events is reasonable, proportionate and appropriate and that no preferential treatment is shown towards specific firms with which we might like to do business.

4. Payments Out

In order to ensure that all payments made by Hourigan Planning Ltd are legitimate and are not intended to be used to finance corrupt behaviour, we have robust financial controls in place to screen all payments before they are made. These include:

The vetting and authorisation of all payment requests by the Finance Commercial / Managing Director to ensure that any potential bribes (including facilitation payments) are identified prior to payment;
Requiring full and complete receipts from employees prior to the authorisation of any expenses payments; and

Facilitation payments are prohibited under the Bribery Act. The Finance / Commercial / Managing Director when scrutinising payment requests will seek to ascertain whether any of the payments we have been requested to make could be classed as ‘facilitation payments’. If any such payments are identified, they will be queried with the relevant employee. We are committed to preventing illegitimate payments being made on behalf of this organisation.

Any employees who have been requested either directly or indirectly to make a facilitation payment should refer this request to The Commercial Director and/or the CEO Managing Director either directly or anonymously via the Public Interest Disclosure Reporting Procedure (see below) in order for them to decide how best to proceed.

5. Communication

5.1. Policies and Procedures

We are committed to communicating our anti-bribery policies and procedures on a regular basis. We believe that regular and consistent communication will help to embed our anti-bribery procedures internally.

5.2. Training

In addition to communicating our policies and procedures to staff, we are also committed to providing our employees with regular training. This ensures that they have the relevant knowledge and skills to be able to recognise potential instances of bribery and apply our policies and procedures correctly.

All new staff complete anti-bribery training at the start of their employment and complete a test to validate their understanding of the internal policies and procedures. Records of completion of the training and tests will be retained on HR files.

Anti-bribery training will be provided to all existing staff on an annual/bi-annual basis and a test must be completed to demonstrate understanding. Records of completion of the training and tests will be retained on HR files.

6. Monitoring and review

In order to monitor and improve our anti-bribery policies and procedures we monitor them on an on-going basis.

6.1. Payments

The Commercial / Managing / Finance Director conducts on-going screening of all payments out in the course of his normal work.

6.2. Training

We monitor the effectiveness of our anti-bribery training by asking employees to complete short assessments once they have completed this to test their understanding.

We ask staff for feedback on our training, and also take account of any industry-wide or regulator-generated good practice guidance when reviewing our anti-bribery training. Our Compliance Officer reviews our training package to ensure that it remains adequate and fit for purpose at least on an annual basis.

6.3. Management Reporting

In order to ensure that senior management is aware of and actively involved in decisions relating to the mitigation of our bribery risks the Board receives a bribery risk report at least on an annual basis. This report includes the annual risk assessment and details of the measures in place to mitigate the risks identified in that assessment (where relevant). It also includes management information demonstrating the effectiveness of the controls in place.

We include bribery-related matters as a standing item on the Board’s meeting agenda. This ensures that the Board is always kept abreast of any bribery-related issues.

Changes which might require changes to be made to our anti-bribery procedures including governmental changes in the jurisdictions in which we operate, instances of bribery and negative press reports will be reported to the Board on a monthly basis, where relevant, as part of the bribery update to the Board. The Board will consider the impact of the reported event on the firm, and will decide on an appropriate amendment to our existing anti-bribery procedures where it considers relevant.

7. Reporting Bribery

Any employees with bribery-related concerns should report these to the The Commercial Director. The The Commercial Director will treat these concerns confidentially, and will consider them in conjunction with the CEO / Managing Director to assess whether an incident of bribery has occurred. Should any employee feel unable to report their concerns to The Commercial Director, they may report them direct to the CEO / Managing Director / Executive Chairman.

Where The Commercial Director and/or the CEO Managing Director considers there to be sufficient grounds to suspect that an instance of bribery may have taken place, they will report the incident to the Serious Fraud Office (SFO) and co-operate fully with any subsequent investigation in to the incident. They may also take disciplinary action against the individual concerned.

Where the The Commercial Director and/or the CEO Managing Director are unable to establish with any certainty that an instance of bribery has taken place it will be at their discretion to decide whether to report the incident to the SFO.