SPECIAL PAYMENTS AND BUSINESS HOSPITALITY

Only legitimate payments may be made by the Group and these must be properly recorded in the accounts.

The giving of gifts may be approved only if it is customary, reasonable and ethical to do so, is not intended to gain unfair business advantage, does not violate any law, and is properly accounted for.

It is unethical for employees or their families to accept business favours where doing so will create the appearance of influencing the employee’s decisions or actions. This includes receiving gifts (either goods or services) valued at more than £25, numerous gifts of smaller value, or any form of pay from suppliers, dealers or customers. This includes tickets to sporting or entertainment or business hospitality events involving an overnight stay and/or involving travel abroad.

Additionally, employees may not offer suppliers, dealers or customers favours or payment or solicit funds from them for any purpose.

Employees must disclose to the company any occasion on which, as a result of or deriving from his/her employment by the Company, he/she is offered or is in receipt of any remuneration or benefit in kind.

Before accepting any level of hospitality beyond lunch or dinner, the express approval of a Director should be obtained. He or she will need to ensure that the hospitality is for the benefit of the Group’s business.

A central record will be kept by each location of any authorised gifts or hospitality received on its behalf by its employees. The recipient is responsible for ensuring that the gift or hospitality has been correctly disclosed on this record. The Managing Director/Directors shall determine whether such gifts may be retained or disposed of.