ANTI-BRIBERY AND CORRUPTION POLICY

Purpose

It is our 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 and corruption.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.

As our head office is based in the UK this Anti-Bribery & Corruption Policy (“Policy”) focuses on compliance with the UK Bribery Act with which we must all comply in respect of our dealings in the UK and abroad.

Whilst our Business Ethics & Conduct Policy provides guidance on common ethics and compliance issues, this Policy focuses specifically on the bribery and corruption risks that may affect the Company’s business from time to time.

The purpose of this Policy is to:

• set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption
• provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

It is a criminal offence to authorise, offer, promise, give, request, or accept a bribe.

Individuals found guilty can be punished by up to ten years’ imprisonment and/or a fine. As an employer if we fail to prevent bribery, we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. Greater penalties may apply under other applicable anti-corruption laws. We take our legal responsibilities very seriously.

In this Policy, third party” means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents and advisers; and employees, staff or you” means any person working for RSD Vantage from time to time.

This Policy does not form part of any employee’s contract of employment and we may amend it at any time.

Scope

This policy applies to all employees and contractors of RSD Vantage.

Risk Assessment

We have identified that the following are particular risks for our business:

Gifts, travel, corporate hospitality and entertainment

As with any organisation, the giving or receiving of gifts, providing or attending corporate hospitality or other entertainment are part of doing business, however, there is always a risk that gifts or entertainment are given or received for the purposes of influencing a person to do something that they should not (for example, awarding a contract unfairly or not following the established process) or to reward a person for refraining from taking an act that may disadvantage the company (for example, imposing a tax levy or fine).

Accordingly, great care must be taken by all employees to ensure that the giving or receiving of gifts or any other entertainment does not go beyond that which is reasonable and proportionate in the context of the particular business relationship.

Employees must think carefully before giving or receiving gifts or entertainment and should consider whether the gift or entertainment being considered could create the appearance of impropriety and raise questions for the Group.

Responsibilities

We are all accountable and must comply with this policy by applying high ethical standards as well as common sense to all situations.

The Director is responsible for implementing the policy.

Basic Standards of Conduct & Responsibilities

All RSD Vantage personnel are expected to adhere to all parts of this Business Ethics and Conduct Policy at all times. The basic standards of conduct are that all of the above shall:

1. Maintain a safe and healthy workplace and protect all RSD Vantage personnel, the general public and the environment through rigorous Health, Safety and Environmental procedures.
2. Ensure quality projects, products and provide excellent customer service
3. Maintain honesty and integrity, avoiding actual or apparent conflicts of interest in personal and professional relationships
4. Provide customers with information that is accurate, complete, objective, relevant, timely and understandable.
5. Comply with all applicable laws, rules and regulations of national, federal, provincial and local governments and other applicable regulatory agencies wherever RSD Vantage operates.
6. Act in good faith, responsibly, and with due care, competence and diligence.
7. Protect the Company’s confidential information, all personal data, third party confidential information, and respect the intellectual property rights of third parties.
8. Conform to all sanctions and export control requirements when conducting business internationally.
9. Strive to promote a diverse working environment through respect for different cultures and applicable laws.
10. Never pay, offer or receive money or give, offer or receive anything of value to:
11. Secure business or the chance of business;
a. Secure favourable treatment;
b. Influence any act or decision; or
c. Induce any act or decision.
12. Not discuss or disclose information about its tender or bid activity with or to any third party.
13. Not discuss or disclose pricing or other commercially sensitive business information with or to any third party.
14. Not discriminate in the selection, hiring, retention, promotion or transfer of qualified individuals based on race, colour, ancestry, place of origin, political belief, religion, marital status, family status, physical or mental disability, sex, sexual orientation, age or other ground specified by law or other regulation.