Anti-Bribery Policy

Introduction

The UK Bribery Act 2010 came into force on 1st July 2011.

The Act makes it an offence to:

• Offer, promise or give a bribe (active bribery) – Section 1

• Request, agree to receive or accept a bribe (passive bribery) – Section 2

• Bribe a foreign public official in order to obtain or retain business or an advantage in the conduct of business – Section 6
• Fail to prevent a person associated with it bribing another person in order to obtain or retain business or an advantage in the conduct of business – Section 7

Bribery is defined as “The offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal or a breach of trust”.

Purpose

The purpose of this document is to serve as a guide for all directors, employees and persons associated with the company.

Copley Scientific has a zero tolerance of bribery and corruption. This policy has been formally approved by the Board of Directors and extends to all the company’s business dealings and transactions in all countries in which it or its subsidiaries and associates operate. All directors, employees of the company and persons associated with it (as defined by the Act) are required to comply with this policy.

Policy

This policy statement applies to all directors, employees and persons associated with the company as defined by the Act.

The company prohibits:

• The offering, promising, giving, accepting or soliciting of any bribe, whether cash or other inducement

To or from:

• Any person or company, wherever they are situated and whether they are a public official, body, private person or company

By:

• Any director, employee, agent or other person or party acting on the company’s behalf

In order to:

• Gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual or
• Gain any commercial, contractual or regulatory advantage for the company in a way which is unethical

The implementation of this policy should not prevent the performance of normal duties provided the activities are customary, appropriate and properly recorded. Acceptable procedures include, for example:

• Normal bona fide hospitality

• Promotional expenditure which seeks to improve the image of the company
• Other business expenditure designed to establish cordial relations

However, market practice varies between countries and what is normal and acceptable in one place may not be in another; moreover ethical values employed by Copley Scientific should underpin any activities undertaken.

Interpretation

Copley Scientific will investigate seriously any actual or suspected breach of this policy, or the spirit of this policy. Employees may be subject to disciplinary action which may ultimately result in their dismissal. If there is doubt as to whether a potential act does not conform to this policy, the matter should be referred to the Operations Manager or member of the Board of Directors.

Any persons associated with the company and/or other third parties found to be bribing or attempting to bribe a Copley Scientific employee, a senior officer, a supplier or a customer will be immediately informed in writing of the fact, business dealings will be ceased and the appropriate authorities informed.