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    Anti-Bribery & Corruption Policy

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    John Geddes
    Antii-Bribery and Corruption Policy

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    Anti-Bribery & Corruption Policy

    Uploaded by

    John Geddes
    3 views1 page
    Antii-Bribery and Corruption Policy

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    Antii-Bribery and Corruption Policy

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    3 views1 page

    Anti-Bribery & Corruption Policy

    Uploaded by

    John Geddes
    Antii-Bribery and Corruption Policy

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 1

    Anti-Bribery & Corruption Policy

    Commitment
    Enerveo has a zero tolerance approach towards any form of corruption, fraud and criminality (including financial
    crime), and the giving or receiving of bribes for any purpose.

    Objectives
    • To maintain our established reputation for lawful and ethical behaviour and for financial integrity in all aspects of
    its business;
    • To minimise Enerveo’s (including its Directors’ and employees’) exposure to bribery, corruption and financial
    crime; and
    • To maintain a culture where bribery or corruption is never acceptable, taking appropriate action where this is not
    adhered to.

    This will be achieved by:


    • Maintaining strict controls and strategies to manage the risks and compliance with legal, regulatory and reporting
    obligations and requirements relating to corruption;
    • Maintaining a strong and positive culture towards ethics and compliance and Doing the Right Thing;
    • Promoting the disclosure and management of potential conflicts of interest;
    • Having zero tolerance in relation to any competition law infringement, competing vigorously and fairly, and with
    full consideration at all times, to its obligations under UK, EU and Irish competition law (together with competition
    laws in any other jurisdiction in which the Enerveo is active); and
    • Making sure that all Enerveo employees and Directors understand and comply with the policy and supporting
    procedures and complete any company training programmes on fraud awareness, competition law, anti-bribery
    and anti-corruption.

    Responsibilities
    • The Executive Board are responsible for the oversight for this policy including the approval of any changes to
    the policy. They support the Policy Owner to make sure that the policy is adhered to through awareness, training
    and monitoring of policy implementation.
    • Incidents and breaches are reviewed and where appropriate opportunities for improvement are actioned.
    • Training will be provided by the legal team to all Enerveo employees and Directors to ensure compliance with
    this policy.
    • There are clear channels for employees to escalate concerns about wrongdoing through line managers and the
    Board's sub-committees.

    Luca Warnke Tom Wood


    Chief Executive Officer Director of Commercial

    PO-COR-0015 October 2021


    Rev: 1.00

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