Aquaris Solutions Anti-Bribery and Corruption Policy

Policy Overview

This policy outlines our commitment to maintaining high ethical standards and our responsibilities in preventing bribery and corruption.

We are dedicated to conducting business honestly and ethically. We have zero tolerance for bribery and corruption and are committed to:

  • Acting professionally and ethically in all our business dealings and relationships.

  • Implementing and enforcing effective systems to counter bribery.

The Bribery Act 2010 outlines two main offences: "active" bribery (offering, promising, or giving a bribe) and "passive" bribery (requesting, agreeing to receive, or accepting a bribe). The Act also establishes corporate liability for failing to prevent bribery.

Individuals found guilty of bribery can face imprisonment for up to ten years, and businesses can face unlimited fines for bribery-related offences committed by their associates.

Our Commitment

We take our anti-bribery and corruption responsibilities seriously. All employees must comply with our procedures to prevent bribery and corruption.

Gifts and Hospitality

With prior authorization, we allow reasonable and proportionate hospitality and business expenditures. However, we recognize that gifts and hospitality can be misused as bribery, so all such exchanges must be reported and authorized.

The giving or receipt of gifts is permitted if:

  • It is not intended to influence a third party for business advantage or as a reward for business retention.

  • It complies with the law.

  • It is given in our business name, not in the name of individuals.

  • It does not include cash or cash equivalents (e.g., gift certificates).

  • It is appropriate in the circumstances (e.g., small gifts at Christmas).

  • It is of appropriate type and value and given at an appropriate time.

  • It is given openly, not secretly.

  • It is not offered to or accepted from government officials or political representatives without prior approval.

The key test is whether the gift or hospitality is reasonable and justifiable.

Unacceptable Practices

We prohibit our employees (or anyone on their behalf) from:

  • Giving or offering a payment, gift, or hospitality expecting a business advantage.

  • Giving or offering a payment, gift, or hospitality to expedite routine procedures.

  • Accepting payments or gifts expecting business advantages for the giver.

  • Accepting gifts or hospitality with the expectation of returning a business favor.

  • Retaliating against anyone refusing to engage in bribery or raising concerns.

  • Engaging in any activity that could lead to a breach of these standards.

Facilitation Payments and Kickbacks

We do not make or accept facilitation payments or kickbacks. Facilitation payments are unofficial payments to expedite government actions, and kickbacks are payments for business favors. All employees must avoid any activity suggesting such payments will be made or accepted.

Responsibilities and Reporting

Preventing, detecting, and reporting bribery and corruption are responsibilities shared by everyone working for or under the control of Aquaris Solutions. All employees must avoid activities that could lead to or suggest a breach of our anti-bribery standards.

Confidential Reporting

We encourage openness and support anyone raising genuine concerns in good faith. We ensure no one suffers detrimental treatment for refusing to accept or offer a bribe or for reporting concerns.

Training and Implementation

Training on this policy is part of the induction process for all new employees and is regularly provided to existing employees. Our zero-tolerance approach to bribery and corruption is communicated to all suppliers, contractors, and business partners at the start of our business relationship and as needed thereafter.

Oversight and Responsibility

Our CEO is responsible for ensuring compliance with our legal and ethical obligations. The relevant Director is responsible for implementing this policy, monitoring its effectiveness, and addressing any queries. Managers are responsible for ensuring their teams understand and comply with this policy and receive adequate training.