Anti-bribery, corruption, and whistleblowing policy

The Company is committed to the highest standards of ethical conduct and integrity in all its business activities and relationships in the UK and overseas. The Company will not tolerate any form of bribery by its workers and is committed to implementing and enforcing this policy.

• payment from a third party that you know, or suspect is offered with the expectation that the Company will obtain a business advantage; and/or
• a gift or hospitality from a third party if you know or suspect it is offered or provided with an expectation that a business advantage will be provided by the Company in return.

Threats or retaliation

Finally, you must not threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy.

Due to the nature of the work completed within Methods there is a risk across all of our sales functions, as there would be in any other business operating within a sales environment. The Company realises the risk and as such regular anti Bribery training will be provided to all workers of the Company.

The Company will authorise only reasonable, appropriate and proportionate entertainment and promotional expenditure, according to the nature of the business relationship.

The Company will not approve business entertainment where it considers that a conflict of interest may arise or where it could be perceived that undue influence, or a particular business benefit was being sought (for example, prior to a tendering exercise).

Gifts are benefits of any type, including in-kind, that are given free of charge, such as: invitations, meals, entertainment etc.

Employees must be wary of gifts and invitations that help to establish good business relations but potentially may be considered, or perceived, to be a means of influencing a decision, favouring a company or an individual. Consequently, gifts can be likened to, or perceived as, active or passive corruption.

Any gifts or invitations other than those with a symbolic value are prohibited. As a result, before offering a gift or invitation, employees must consult this policy and check whether the value of the gift or invitation falls within the category of symbolic value, the only category permitted.

Example

During the year's end festive season, an employee wishes to offer a scarf to a client to thank them for their hard work on a complex project. The Employee must check the gifts and hospitality Section of this policy. If the scarf's value exceeds the cap permitted under the gifts and hospitality policy, they may not offer that gift.

Any gifts, rewards or entertainment received or offered from clients, public officials, suppliers, or other business contacts should be reported to the Head of Delivery Support and Assurance.

In certain circumstances, you may be asked to return gifts to the sender or refuse the entertainment where it could lead to a breach of this Policy. As a general rule, small tokens of appreciation, such as flowers or a bottle of wine, may be retained by colleagues.

If you wish to provide gifts to suppliers, clients, or other business contacts, prior written approval is required from the Head of Delivery Support and Assurance, or if by a Director, by the COO. Details of the intended recipients, reasons for the gift, and the business objective must be supplied. Such gifts will be authorised only in limited circumstances and will be subject to a cap of £100 per recipient.

The Company does not make, and will not accept, facilitation payments. Facilitation payments are usually small, unofficial payments made to secure or speed up a routine government action by a government official. You are therefore prohibited from making or accepting any facilitation payments and must avoid any activity that might lead to, or suggest, that a facilitation payment has been accepted by the Company.

If you have any suspicions, concerns or queries regarding a payment you should report immediately to the Head of Delivery Support and Assurance. (please see reporting bribery or suspected bribery below).

Through patronage and sponsorship, the Methods group may wish to offer financial or material support to a project, social, cultural, or sporting initiatives in order to communicate and promote its values and are legal and ethical under the local laws and practices. This is a company decision, though.

Patronage and sponsorship initiatives require approval from the COO.

No donation must be offered or made without prior approval. Such actions must be carried out without seeking any advantage other than promoting the image of the Methods group.

We are committed to improving our practices to combat slavery and human trafficking. Methods takes its obligations under the Modern Slavery Act 2015 seriously and has robust working practices to comply with its obligations.

As part of this we encourage all colleagues to report any concerns about labour standards and potential Modern Slavery that they may suspect or witness within Methods, or our suppliers, to the Head of Delivery Support and Assurance.

Any concerns will be treated confidentially and will be followed up through the appropriate channels such as audit, and reporting to the authorities.

Colleagues should never tackle suspicion of Modern Slavery independently or approach individuals at risk, as this could put themselves and the individuals at risk.

If you are (i) offered a bribe by a third party, or (ii) are asked to make a bribe, or (iii) suspect that this may happen in the future, or (iv) believe that you are a victim of another form of unlawful activity or, (v) see, experience or hear anything that makes you suspect any of these, this should be reported to the Head of Business Assurance as soon as possible.

The Company is committed to ensuring that no-one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.

If you believe that you have suffered an such treatment, you should inform your line manager, or the Head of Delivery Support and Assurance or the Head of HR immediately. If the matter is not remedied, and you are an employee, you should raise this formally using the Company’s Grievance Procedure or directly with the COO.

Any member of the board may be approached for matters relating to issues that cannot be discussed at the levels of management cited above.

Methods is committed to protecting any whistle-blowers who, in good faith and without self-interest, report any incidents of which they have become aware in exercising their duties that are unlawful or contrary to the public interest.

You’re a whistle-blower if you’re a colleague or contractor and you report certain types of wrongdoing. This will usually be something you’ve seen at work. The wrongdoing you disclose must be in the public interest. This means it must affect others, for example the general public.

As a whistle-blower you’re protected by law. You will not be treated unfairly or lose your job because you ‘blow the whistle’.

You can raise your concern at any time about an incident that happened in the past, is happening now, or you believe will happen in the near future.

These may include a crime, offence, or serious risk to public health. In economic terms these may also include the offences of corruption, influence peddling or the unlawful taking of interest.

Complaints that count as whistleblowing, where you are protected by law, include reporting any of the following:

• a criminal offence, for example fraud
• where someone’s health and safety is in danger
• risk or actual damage to the environment
• a miscarriage of justice
• where the company is breaking the law, for example does not have the right insurance
• where you believe someone is covering up wrongdoing.

Complaints that don’t count as whistleblowing:

Personal grievances (for example bullying, harassment, discrimination) are not covered by whistle- blowing law, unless your particular case is in the public interest. These should be reported under the Company’s grievance procedure.

Making your claim anonymously:

You can report safely to a senior manager, Portfolio director, COO, HR or the Head of Delivery Support and Assurance. Any member of the board may be approached for matters relating to issues that cannot be discussed at the levels of management cited above.

Should you wish to report your concern anonymously the Suggestion Box on The Moogle. may be contacted for internal whistle blowing and to ensure anonymity.

What we will do when you report whistleblowing:

The person you report the issue to will listen to your concern and decide if any action is needed. You may be asked for further information.

You must say straightaway if you do not want anyone else to know it was you who raised the concern.

You will not have a say in how your concern is then dealt with by the Company.

We will keep you informed about the action taken but may not be able to give you much detail if they have to keep the confidence of other people.

www.gov.uk/whistleblowing

All existing colleagues will receive annual training through the e learning platform. All new starters will complete the training during induction and receive access to this policy.

The Company will communicate its anti-bribery and corruption measures to you as appropriate. In addition, the Company’s zero tolerance approach to bribery and corruption will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

You must read, understand, and comply with this policy (and any future policy updates that may be issued from time to time by the Company).

Any breach of this policy may lead to disciplinary action by way of the Company’s disciplinary policy, this in turn could result in dismissal for gross misconduct. Please refer to the Company’s Disciplinary policy.

Any instruction to cover up wrongdoing is also a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, you should not agree to remain silent.

Please refer to Reporting Bribery or suspected wrongdoing above.

Contractual relationships with other parties may also be terminated should they breach this policy.

The Board of Directors has overall responsibility for ensuring both that this policy complies with our legal and ethical obligations, and that all those under the Company’s control comply with it.

All levels of management are responsible for ensuring that those reporting to them are made aware of and understand this policy and are given appropriate training and induction.

The Head of Delivery Support and Assurance with the support of HR and Finance will monitor and review the implementation and effectiveness of this policy and related procedures on a regular basis. This will include reviewing internal financial systems, expenses, corporate hospitality, gifts and entertainment policies.

The success of this Policy depends on all colleagues playing their part in helping to detect and eradicate bribery. Therefore, you are invited to comment on the effectiveness of this policy or suggest ways in which it may be improved. Such comments should be addressed to the Head of Business Assurance, Head of HR, or COO.

This policy does not form part of any employee’s contract of employment, and it may be amended at any time.