Anti-Bribery & Corruption Policy

Anti-Bribery & Corruption Policy

Introduction

It is Third Bridge’s policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, and implementing and enforcing effective systems to counter bribery. Third Bridge expects the same approach from all those with whom we do business.

This policy sets out Third Bridge’s position on bribery and corruption.

What is bribery?

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

Bribery includes:

  • Payments to a company’s employees or their relatives, or to those of a third party, to secure a business advantage
  • Gifts, hospitality and expenses payments made to secure a business advantage
  • Political contributions made to secure a business advantage
  • Facilitation payments or "kickbacks" made to secure or accelerate routine or necessary business actions

Scope

This policy applies to all Third Bridge’s employees and associated persons acting on behalf of Third Bridge, and extends to our business dealings in all jurisdictions within which we operate.

Policy

Third Bridge does not engage in bribery or corruption. It is contrary to Third Bridge’s policy for any employee or third party acting on behalf of Third Bridge to request, offer, solicit, make or receive any payments or inducements which are illegal, unethical or represent a breach of trust.

Third Bridge respects all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, particularly laws that are directly relevant to specific or local business practices.

Third Bridge will not do business with any person or company which we know (or have reasonable grounds for suspecting) engages in bribery or corruption.

Responsibilities

The board of directors is responsible for establishing this policy within Third Bridge which prohibits bribery and corruption involving Third Bridge employees or any third parties acting on behalf of Third Bridge.

Each Third Bridge employee receives training in respect of this policy and it is the responsibility of each Third Bridge employee to ensure compliance with the terms of this policy. If any employee believes that the terms of this policy are not being correctly adhered to then they should seek to raise their concerns with their line manager as soon as possible.

Compliance

Compliance with this policy will be subject to regular review and audit, to ensure it remains suitable, effective and proportionate having regard to Third Bridge’s operations and the jurisdictions within which we operate.

Any concerns raised by any person relating to any alleged non-compliance with the terms of this policy will be immediately investigated and, if appropriate, action will be taken. The General Counsel will report to the Board on any such concerns and the outcome of any investigations conducted into such issues.

Failure to observe the terms of this policy may constitute a disciplinary offence and may expose individuals to civil or criminal proceedings.