Collabit Software Anti-bribery & Corruption Policy

The Bribery Act 2010 came into force on 1 July 2011 and creates a framework of five
criminal offences:

• Giving, promising, and offering of a bribe
• Agreeing to receive or accept a bribe
• Bribing a foreign official
• Failure of commercial organisations to prevent bribery
• A senior officer of a commercial organisation consenting to or conniving in an act of bribery

Collabit Software will conduct business in an honest and ethical manner. Collabit Software
takes a zero-tolerance approach to bribery and corruption and is committed to acting
professionally, fairly and with integrity in all its business dealings and relationships, wherever
it operates, and implementing and enforcing effective systems to counter bribery. Collabit
Software will uphold all laws relevant to countering bribery and corruption in all the
jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010, which
applies to conduct both in the UK and abroad.


All Collabit Software employees and others acting on behalf of Collabit Software must
comply with this Anti-Bribery and Corruption Policy and it extends to all business dealings
and transactions in the UK and in all countries in which Collabit Software operates. It is
essential that Collabit Software conducts an effective process of due diligence prior to
entering into significant business relationships and that a record is kept of this process. Any
breach of the policy is likely to constitute a serious disciplinary, contractual and criminal
matter for the individual concerned. This could constitute gross misconduct for which an
offending employee may be dismissed with

Gifts and Hospitality

This policy does not prohibit normal and appropriate gifts and hospitality (given and
received) to or from Third Parties unless otherwise specifically stated. However, any gift or

• must not be made with the intention of improperly influencing a Third Party or Worker to
obtain or retain business or a business advantage, or to reward the provision or retention of
business or a business advantage, or in explicit or implicit exchange for favours or benefits;
• must comply with local law in all relevant countries;
• must be given in the name of the organisation, not in an individual’s name;
• must not include cash or a cash equivalent;
• must be appropriate in the circumstances;
• must be given openly, not secretly.

Facilitation payment and ‘kickbacks’

Collabit Software does not make, and will not accept, facilitation payments or “kickbacks” of
any kind, such as small, unofficial payments made to secure or expedite a routine government
action by a government official, or payments made in return for a business favour or

Charitable donations and sponsorship

Collabit Software only makes charitable donations and provides sponsorship that are legal
and ethical under local laws and practices and which are in accordance with Collabit
Software’s internal policies and procedures.

Record keeping

Collabit Software maintains appropriate financial records and has appropriate internal
controls in place which evidence the business reason for gifts, hospitality and payments made
and received.

Responsibilities and raising concerns

The prevention, detection and reporting of bribery and other forms of corruption are the
responsibility of all those working for Collabit Software or under our control. All employees
are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees are required to notify Collabit Software as soon as possible if it is believed or
suspected that a conflict with this policy has occurred, or may occur in the future, or if they
are offered a bribe, are asked to make one, suspect that this may happen in the future, or
believe that they are a victim of another form of unlawful activity.