Company Name: RITVARS RADVILAVICS LTD
Company No: 11040640
Introduction
This Anti-Bribery and Corruption Policy (the “Policy”) is designed to affirm RITVARS RADVILAVICS LTD’s commitment to conducting all its business ethically and in compliance with the Bribery Act 2010 (the “Act”), as well as globally applicable anti-bribery laws. This Policy applies to all directors, officers, employees, agents, contractors, suppliers, and associated persons (collectively, “Personnel”) acting for or on behalf of RITVARS RADVILAVICS Ltd.
Scope
The Policy is applicable to all RITVARS RADVILAVICS Ltd activities in the United Kingdom and abroad, and extends to all Personnel and any individuals or organisations who provide services on behalf of the company. The Policy must be adhered to when conducting any business dealings to ensure transparency, honesty, and integrity in all interactions, in line with UK law and the jurisdictional reach of the Act, as well as other relevant legislation in any location where RITVARS RADVILAVICS Ltd conducts business.
1. Principal Criminal Offences under the Bribery Act 2010
1.1 Bribing Another Person
Personnel must not, either directly or indirectly, offer, promise, or give any financial or other advantage with the intention of:
• Inducing or influencing any person to improperly perform their business or public functions; or
• Rewarding a person for improperly performing their business or public functions.
1.2 Being Bribed
Personnel must not request, agree to receive, or accept any financial or other advantage with the knowledge or intent that such action will lead to the improper performance of their own public or business functions.
1.3 Bribing a Foreign Public Official
Personnel must not offer, promise, or give any financial or other advantage to a Foreign Public Official (“FPO”) to influence the official’s performance of their official duties, thereby securing business or a business advantage. The only exception is where the FPO’s governing laws expressly allow for the advantage provided.
1.4 Failure by a Commercial Organisation to Prevent Bribery
RITVARS RADVILAVICS Ltd may be liable for the failure to prevent bribery committed by an associated person, unless it can demonstrate that it had in place “adequate procedures” designed to prevent such conduct.
2. Definitions
• Foreign Public Official (“FPO”): An individual holding a legislative, administrative, or judicial position of any kind outside the UK, or performing a public function on behalf of a government entity.
• Associated Person: An individual or entity performing services for or on behalf of RITVARS RADVILAVICS Ltd, including employees, contractors, agents, suppliers, joint venture partners, and subsidiaries.
• Adequate Procedures: Procedures in place that are deemed adequate to prevent associated persons from engaging in bribery. Guidance on what constitutes adequate procedures is provided in government resources and incorporates principles of proportionality, risk assessment, due diligence, communication, training, and monitoring.
3. Prohibited Practices
3.1 Facilitation Payments
Facilitation payments, defined as unofficial payments made to public officials to secure or expedite routine actions, are strictly prohibited by this Policy and are illegal under the Act, regardless of customary practices in certain countries.
3.2 Hospitality and Gifts
RITVARS RADVILAVICS Ltd prohibits the offering, accepting, or provision of hospitality, gifts, or entertainment that could be perceived as improper or as an attempt to gain unfair advantage. Permissible hospitality must be:
• Provided in good faith, directly related to legitimate business discussions or relationships; and
• Proportionate and compliant with the usual hospitality practices within the industry.
4. Key Principles of Compliance
4.1 Proportionate Procedures
The procedures established to prevent bribery must be proportionate to RITVARS RADVILAVICS LTD’s identified risks and business scope, ensuring effective implementation.
4.2 Top-Level Commitment
Senior management affirms a zero-tolerance approach to bribery and corruption, fostering a culture where unethical behaviour is categorically unacceptable.
4.3 Risk Assessment
Regular, documented assessments are to be conducted to identify and mitigate potential bribery risks, considering factors such as geographical location, industry practices, and relationships with third parties.
4.4 Due Diligence
Due diligence checks are to be conducted on Personnel and associated persons, especially in high-risk roles or regions. This may include background checks, compliance with RITVARS RADVILAVICS LTD’s ethical standards, and verification of any historical corruption involvement.
4.5 Communication and Training
All Personnel will receive clear communication and training regarding the anti-bribery measures and obligations under this Policy. Training is to be mandatory upon induction and refreshed periodically.
4.6 Monitoring and Review
The Policy and its procedures will undergo regular review and, where necessary, updates to maintain alignment with legal and regulatory requirements and to improve effectiveness.
5. Reporting Concerns
RITVARS RADVILAVICS Ltd encourages all Personnel to report any suspicion of bribery or corruption promptly, either through internal reporting channels or anonymously if desired. Retaliation against individuals who raise concerns in good faith is strictly prohibited. All reports will be investigated promptly, and appropriate corrective action will be taken where necessary.
6. Disciplinary Action
Any breach of this Policy may result in disciplinary action, up to and including termination of employment or contractual relationship. Violations of the Bribery Act can also lead to criminal prosecution, resulting in fines or imprisonment for individuals, and unlimited fines for RITVARS RADVILAVICS Ltd.
7. Policy Monitoring and Responsibility
The responsibility for implementing and monitoring this Policy lies with the Board of Directors, who will oversee regular reviews, updates, and the Policy’s effective dissemination throughout RITVARS RADVILAVICS LTD’s operations globally. The Board commits to establishing necessary resources and support to uphold the Policy and ensure strict compliance.
8. Conclusion
RITVARS RADVILAVICS Ltd is steadfast in its commitment to conducting business in a manner that is both ethical and compliant with anti-bribery laws worldwide. All Personnel are required to understand and uphold this Policy to preserve RITVARS RADVILAVICS LTD’s integrity and reputation.
Signed by an authorised signatory of RITVARS RADVILAVICS LTD
__________________________ Date: _________________
Ritvars Radvilavics (Director)