Anti-Bribery and Anti-Corruption Policy

1Policy statement

1.1Eurabelt Fuels Ltd has zero tolerance of bribery and corruption in any form. CSR contributions are made to support the work of partner organisations under the framework, and never to obtain or retain business, to influence a decision or to secure any advantage.

2Scope

2.1This policy applies to the directors, employees and representatives of Eurabelt, to anyone acting on its behalf in connection with the CSR programme, and to every partner organisation in its dealings under the framework.

3The law

3.1Eurabelt complies with the Bribery Act 2010 of the United Kingdom, which makes it an offence to offer, promise or give a bribe, to request, agree to receive or accept a bribe, to bribe a foreign public official, and, for a commercial organisation, to fail to prevent bribery by a person associated with it. Eurabelt also complies with the anti-corruption laws of every other jurisdiction in which it is registered or in which a partner operates.

4Prohibited conduct

4.1No person covered by this policy may:

• offer, promise, give, request, agree to receive or accept any payment, gift, hospitality or other advantage intended to induce or reward the improper performance of a function or activity;
• offer or give any advantage to a public official to influence that official in the performance of official functions;
• make a CSR contribution, or recommend one, as an inducement or reward to any person, or at the request of a public official or a business counterparty;
• route any payment to a person, organisation or account other than the approved partner named in a signed written agreement;
• make or record any false, misleading or incomplete entry in the books or records of the programme.

5Unofficial payments to officials

5.1Small unofficial payments made to secure or speed up a routine government action are bribes under the Bribery Act 2010. They are prohibited, whatever their amount and whatever local practice may be.

5.2The only exception is a payment made under duress, where a person faces an imminent threat to life, liberty or physical safety. Any such payment must be reported to Compliance as soon as possible and recorded.

6Gifts and hospitality

6.1Gifts and hospitality may be given or received only where they are reasonable and proportionate, given openly, permitted by law and by the rules of the recipient’s organisation, and not connected with any pending decision, application or assessment.

6.2No gift or hospitality of any value may be offered to or accepted from an organisation whose application is under assessment. Cash and cash equivalents are never permitted. Anything of more than modest value must be declared to Compliance, who keeps a register of gifts and hospitality.

7Political donations

7.1No political donation of any kind is made through the CSR programme, and no CSR contribution may be made to a political party, a candidate, an elected official or an organisation controlled by any of them.

8Partner organisations

8.1Partner organisations must hold documented anti-bribery and anti-corruption policies appropriate to their size and activities, must use support only for the purpose agreed in writing, and must keep records that allow every use of funds to be traced. Breach of this policy by a partner is grounds for suspension and termination under EBF-CSR-POL-07.

9Reporting concerns

9.1Anyone who is asked for, offered or suspects a bribe or any other breach of this policy must report it promptly, as set out in the Complaints and Speak-Up Policy (EBF-CSR-POL-11), to compliance@eurabeltfuels.eu. No one will suffer detriment for refusing to pay or accept a bribe, or for raising a concern in good faith, even if it turns out to be mistaken.

10Consequences and review

10.1A breach of this policy by a director, employee or representative may lead to disciplinary action, including dismissal or termination of engagement, and may be reported to the authorities. This policy is owned by Compliance and reviewed at least once a year.