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Anti-Bribery Policy

Introduction and Commitment

Oakland is committed to conducting its business ethically and with integrity. We have a zero-tolerance approach to bribery and corruption in all its forms, whether direct or indirect, and we are fully committed to complying with the UK Bribery Act 2010, as well as all other applicable anti- bribery laws and regulations in the jurisdictions where we operate.

This policy applies to all employees, directors, officers, contractors, consultants, agents, and any other individuals or entities acting on behalf of Oakland (collectively referred to as “Associated Persons”).

We recognise that bribery and corruption can take many forms and can occur anywhere in the world. Even though we operate overseas, we are committed to upholding standards that are no lower than those required by UK law. This policy outlines our commitment to preventing, detecting, and addressing bribery and corruption.

Our commitment and your obligations

We are committed to integrity and fairness across all our operations. We do not tolerate bribery or corruption.

If you are employed or engaged by the Company, or are in any other way involved with us or under our control, you must help prevent and detect bribery or corruption in our business.

You must report any conduct or activity that you believe or suspect amounts (or could in the future amount) to bribery or corruption to your manager or a Company director. Our Whistleblowing Policy has more information about raising these types of concerns.

Any report will be taken extremely seriously. We will not treat you unfavourably for having refused to become involved in bribery or corruption, or for flagging up your concerns to us in good faith. If you do suffer any negative treatment in this context, you must talk to your manager. If you are not satisfied that the issue has been resolved, you could raise a grievance under our Grievance Policy.

You must not threaten or otherwise treat badly anyone who refuses to become involved in bribery or corruption, or who has reported or is considering reporting a bribery or corruption-related issue to us.

What is bribery?

We define bribery as a reward or inducement for acting improperly, illegally or unethically to gain an advantage, whether personal, commercial, or regulatory. You do not need to have actually given or received the reward or inducement for this to amount to bribery. A bribe does not need to involve money. Offering hospitality, entertainment or gifts can also be classed as bribery if the purpose is to exert influence. You could face up to 10 years in prison for offering, promising, giving, asking for, or accepting a bribe, as this is a criminal offence. We may as a Company also face sanctions if we don’t stop bribery taking place. This can include an unlimited fine and being excluded from public contract tenders.

This list includes the most common actions we consider to be bribery, but it doesn’t cover everything. You must not become involved in any of these things, or allow anyone else to become involved in them on your behalf:

What is corruption?

We define corruption as the abuse of power, authority, or position in return for some personal advantage.

What is allowed?

Offering or receiving hospitality and entertainment from third parties is allowed under this policy, provided it is appropriate and reasonable in the circumstances and the purpose is to:

It is generally fine to give or receive low-value business-related gifts, such as books or branded pens and stationary.

You can reimburse a third party for business-related expenses – the costs of attending a meeting, for example – and you can also accept a third party’s offer to pay your expenses. This will not normally be bribery.

However, a payment made or received that exceeds reasonable or genuine business expenses is not acceptable. An example would be payment for an extended stay in a hotel, before or after business had been concluded.

What are kickbacks and facilitation payments?

We don’t make or receive kickbacks or facilitation payments. We define kickbacks as payments made in return for a business advantage or favour.

We define facilitation payments as unofficial (and usually small) payments, made to speed up or smooth out a routine process or activity. They are sometimes described as “back-handers”. Recipients typically include government or other officials.

You must avoid being put in a position where you might be asked to make or accept a kickback or facilitation payment on our behalf. You must also avoid being put in a position from where it could be inferred that such a payment was available. If anyone asks you to make a payment on behalf of us, you must consider carefully whether what they’re asking for is in proportion to the goods or services involved. Always get a receipt, and if you have any concerns you must discuss them with your manager straightaway.

Risk assessment

Oakland will conduct regular and comprehensive risk assessments to identify and evaluate the potential bribery risks to which our business is exposed. This will include considering factors such as:

The risk assessment will be held within our online ISMS risk register and will be reviewed and updated at least annually, or more frequently if there are significant changes to our business or operating environment. The findings of the risk assessment will inform the development and implementation of appropriate anti-bribery controls and procedures.

Continuous monitoring of procedures

Oakland is committed to continuously monitoring the effectiveness of its anti-bribery procedures. This will involve:

The results of our monitoring activities will be used to identify areas for improvement and to ensure that our anti-bribery program remains robust and fit for purpose.

Reporting channels

Oakland encourages all staff and associates to report any concerns or suspicions of bribery or corruption. We have established clear and confidential reporting channels to facilitate this: