Anti-Bribery and Corruption

1.0 Purpose

Culligan, and its associated companies, (“the Company”, “us”, “we”) is committed to applying the highest standards of ethical conduct and integrity to all its business and in all jurisdictions in which it operates. When acting on behalf of the Company you are responsible for maintaining the Company’s reputation and for conducting business honestly and professionally. The integrity and reputation of the Company depends on the honesty, fairness and integrity brought to the job by everyone associated with the Company; bribery is a criminal offence.

A bribe is defined as a financial advantage or other reward that is offered to, promised to, given to, or received by an individual or company to induce or influence that individual or company to perform its public or corporate functions or duties in an improper manner (i.e. not in good faith, not impartially, or not in accordance with a position of trust).

2.0 Scope

The Company’s anti-bribery policy applies to all team members “the employee” whether permanent or temporary, full-time or part-time, officers, agents, consultants or any person or persons or other entities acting for it or on its behalf. It applies also to all those with whom we do transact, or potentially may transact business in any capacity. It applies worldwide.

The Company reserves the right to alter or refresh this policy or any of its terms at any time. This policy does not form part of your contract of employment.

3.0 Policy

The Company will not tolerate any form of bribery, whether direct or indirect, by, or of, its team members, officers, agents, consultants, agency workers, contractors or any persons or companies acting for it or on its behalf.

The Directors are committed to implementing and enforcing effective systems throughout the Company to prevent, monitor and eliminate bribery, in accordance with its obligations under all relevant anti- bribery legislation in whatever jurisdiction we operate.

The Company will not conduct business with third parties including clients, suppliers, agents or representatives who are not prepared to support its anti-bribery objectives.

The Company will not make contributions to any political party or to any organisations or individuals engaged in politics as a means to obtain any business advantage.

Any breach of the Company’s policy will normally be treated a gross misconduct and the team member engaged in such breach will face disciplinary action up to and including summary dismissal.

What is not acceptable?

All team members and any other person acting on behalf of the Company are prohibited from offering, giving, soliciting or accepting any bribe, whether cash or other form of inducement to or from any person or company in order to gain any commercial, contractual or regulatory advantage for the Company in a way which is unethical or in order to gain any personal advantage, monetary or otherwise, for themselves or anyone connected with them.

In the course of providing services to clients, or dealings with suppliers, or any other person having similar connections to the Company, team members should under no circumstances accept cash or cash equivalent items such as vouchers.

Gifts or other forms for reward of indefinite, or possible material value must not be accepted by any team member without the prior consent of their manager. The test of materiality to be applied is whether, in all circumstances, the gift or hospitality is reasonable and justifiable. The intention behind the gift and its timing should always be considered.

Receipt of any gift of any description from, or provision of gifts to, potential customers or suppliers during any kind of active negotiations, is strictly prohibited.

What is acceptable?

The Company will continue to provide bona fide hospitality to clients and incur promotional expenditure. However, all such expenditure must be transparent, proportionate, reasonable and authorised in advance.

Inevitably, decisions as to what is acceptable may not always be easy. Promotional items such as desk calendars, pens or a bunch of flowers to mark a special occasion or event, may be accepted. If anyone is in doubt as to whether a potential act constitutes bribery, the matter must be referred to your manager or a Director before proceeding.

The giving and exchange of small gifts at appropriate times e.g. Christmas in the UK and Ireland is acceptable.

Implementation

All team members and any other individuals acting on behalf of the Company are required to familiarise themselves with and comply with this policy which will form part of every new team member’s induction and onboarding programme.

The Company depends on all team members, and those acting for the organisation, to assist in the prevention of bribery. Therefore, all team members and others acting for, or on behalf of, the Company are expected to report any suspected bribery to the Company in accordance with this Policy. This may be done to a Director of your choice on a confidential basis.

You must declare and keep a written record of all hospitality or gifts accepted or offered which will be subject to managerial review.

You should note that all Expenses Claim Forms will contain a statement that any and all claims submitted fully comply with this Policy, and you must ensure that all expenses claims relating to hospitality, gifts or expenses incurred to third parties comply with the Expenses Policy and specifically record the reason for the expenditure.

All team members will receive the full support of the Company if they report a suspected bribery in good faith, even if, following investigation, it is found that no bribery took place.

Last Updated: July 2022