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ANTI-BRIBERY AND CORRUPTION POLICY

Elite Metal Group aims to prevent bribery by associated persons through proportionate, clear, practical, accessible and effectively implemented anti-bribery policies and procedures.

The top-level management of Elite Metal Group are committed to preventing bribery by persons associated with it. Elite Metal Group foster a culture within our company in which bribery is never acceptable.

 

1.0 Internal and external communication of the commitment to zero tolerance to bribery

Elite Metal Group are committed to carrying out business fairly, honestly and openly and will adhere to the following;

  • Fully assisting law enforcement in prosecuting anyone who commits a bribery offence.
  • Avoiding doing business with people who do not openly commit to doing business without bribery.
  • Openly articulating the benefits of doing business without bribery, and the range of bribery prevention procedures that Elite Metal Group follows.
  • The Elite Metal Group has key individuals who ensure that there is development and implementation of the anti-bribery procedures across the company.

Elite Metal Group assesses the nature and extent of its exposure to potential external and internal risks of bribery on its behalf by persons associated with it. The assessment is periodic, informed and documented.

Elite Metal Group applies due diligence procedures, taking a proportionate and risk based approach, in respect of people who perform or will perform services for or on behalf of Elite Metal Group in order to mitigate identified bribery risks.

 

1.1 Appraisal and continued monitoring of recruited or engaged ‘associated’ people may also be required, proportionate to the identified risks

Elite Metal Group seeks to ensure that its bribery prevention policies and procedures are embedded and understood throughout the company through internal and external communication. Anyone who performs services for or on behalf of Elite Metal Group is an associated person under the Bribery Act and Elite Metal Group will communicate their anti-bribery policy and procedures to all parties that fall within this category.

Elite Metal Group incorporate in its recruitment and human resources procedures an appropriate level of due diligence to mitigate the risks of bribery being undertaken by employees.

The Elite Metal Group induction given to all new employees will contain concise training on anti-bribery and Elite Metal Group procedures for dealing with bribery. After the initial induction training Elite Metal Group will provide effective refresher sessions at appropriate intervals.

Elite Metal Group monitors and reviews procedures designed to prevent bribery by persons associated with it and make improvements where necessary.

Elite Metal Group has systems to deter, detect and investigate bribery. The continuous monitor on financial transactions will help to detect unethical transactions and surveys and questionnaires will help Elite Metal Group to identify the need for refresher training and improvement of anti-bribery policies.

Elite Metal Group performs formal periodic reviews and reports for top-level management.

Elite Metal Group engages external verification or assurance of the effectiveness of anti-bribery procedures.