Anti-Bribery & Corruption Policy

1.0 Purpose  

The purpose of this policy is to state Lucion’s position and provide information and guidance on the company’s procedures and expectations regarding anti-bribery and corruption. 

2.0 Scope  

This policy applies to all employees of Lucion, (including but not limited to consultants, contractors and agency workers) and anyone who could be deemed as an ‘Associated Person’.  

3.0 Bribery  

A bribe is an inducement, reward or anything of value including any financial or other advantage given, offered, requested, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage, or to improperly influence any act or decision of any person. Corruption is the misuse of entrusted power for private gain.  

Employees or Associated Persons of Lucion Group must not offer, provide, authorise, request or receive bribes or anything that could give the perception of a bribe.   

The UK Bribery Act 2010 (“the Act”) is the legislation on which this policy is based. It creates three potential offences for UK registered companies:  

• A general offence of offering or receiving bribes  
• A specific offence of failing to prevent bribery on behalf of the company  
• A specific offence of bribing a foreign public official  

All employees are provided with Anti-Bribery training to enable them to identify types of bribery, failing to prevent bribery and bribes, gifts and hospitality. To this end Lucion Group is fully committed to instilling a strong anti-corruption culture and is fully committed to compliance with all anti-bribery and anti-corruption legislation including, but not limited to, the Bribery Act 2010 and ensures that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.    

3.1 General Offence of Offering or Receiving Bribes  

This offence is committed if a person (individual or company) offers, promises, gives or receives a bribe. A bribe can include money or any offer, promise or gift of something of value or advantage. It need not necessarily be of large value. It might include signing bonuses or overpaying government suppliers. It might also include intangible benefits such as the provision of information or advice or assistance in arranging a business transaction. It need not be for personal benefit. For example, a donation by a supplier to a favourite charity could be considered a bribe under this legislation.  

3.2 Specific Offence of Failing to Prevent Bribery on Behalf of the Company  

This is a corporate offence. It is committed if a company fails to prevent persons (employees or Associated Persons) from using bribery with the intention of obtaining or retaining a business advantage for the company. For this offence it is irrelevant whether or not the company approves of or is aware of the bribery being committed. It is, however, a full defence to this corporate offence if the company can show that, despite a particular case of bribery, it nevertheless has ‘adequate procedures’ in place to prevent bribery.  

3.3 Specific Offence of Bribing a Foreign Public Official  

This offence is committed if the person giving the bribe intends to influence the foreign public official in the performance of his or her official functions to obtain an advantage in the conduct of business by doing so.  

Whilst such activity is very likely to involve conduct that amounts to ‘improper performance’, it does not have to be proved and could include the performance of their normal public duties which the foreign public official may otherwise have done in any event. Accordingly, extra care should be taken and legal advice sought when dealing with foreign public officials and politicians.  

If in doubt about any issue raised in this Policy, guidance should be sought from your line manager, the Group HR Director or the CEO.  

4.0 Facilitation Payments and other payments  

A “facilitation payment” is an unofficial payment (usually, but not necessarily, made to a public official) to encourage the recipient to perform their existing obligations or role, or expedite or refrain from performing a routine task they are otherwise obligated to do. They are also known as gratuity or “grease” payments. These can be payments to perform routine tasks such as obtaining permits, licenses or other official documents, processing governmental papers, such as visas and work orders or providing power and water supply and loading and unloading cargo.  

Lucion Group prohibits its officers, employees and Associated Persons from offering, making or paying any “facilitation payments” to any third party including, but not limited to, foreign public officials.   

All Lucion Group officers and employees must report to the CCO, CFO and CEO any request by a third party for a facilitation payment.  

All payments are controlled through a purchase order system in to prevent fraud and malpractice, with only personnel in the Finance Team having control over payment and authorisation levels, with higher values requiring multiple authorisations.  

Rigorous financial auditing on an annual basis is undertaken by independent financial auditors to ensure that financial statements are free from misstatement or whether they are inaccurate due to fraud or error.  

Subcontractors are engaged on a contract basis, with clear terms and conditions stipulated in order to maintain transparency and prevent any aspect of fraud, collusion or anti-competitive practise, either between or within Lucion Group companies or the subcontractor companies. Lucion Group companies do not work with or enter into agreements with other organisations to deliver a service which we are able, and have the resource capacity, to provide. Clients and accreditation and certification bodies are made aware of the arrangements we have in place.  

5.0 Political Contributions  

5.1 Political contributions by or on behalf of or in the name of Lucion Group  

Lucion Group funds and resources are not to be used to contribute to any political campaign, political party, political candidate or any of their affiliated organisations. Lucion Group will not use charitable donations as a substitute for political payments.  

5.2 Personal political contributions by employees and other individuals  

Lucion Group recognises that everyone has a right to participate as individuals in the political process and to make personal political contributions from personal funds and in their own time. Officers and employees cannot, however, be reimbursed or otherwise compensated by Lucion Group for any such contribution.  

6.0 Charitable Contributions and Sponsorship  

Lucion Group and its officers and employees may only make charitable contributions or sponsorships on behalf of or in the name of Lucion Group for bona fide charitable purposes and where the activities are aligned with Lucion Group business objectives and values.  

Charitable contributions or sponsorships should be given with the expectation that no tangible benefit is received or expected by Lucion Group. They should never be used as a substitute for political contributions.  

All requests for charitable contributions and sponsorship must first be sent to the relevant line manager and CEO for approval and shall be recorded in an appropriate register.  

7.0 Gifts and Hospitality  

Neither the law, nor this policy is intended to prohibit the giving or receipt of reasonable and proportionate hospitality designed to cement business relationships and enhance knowledge of people, products or services.  

More care is required when giving hospitality or entertainment to public officials, because of the different definition of what constitutes an offence with regards to such persons (see Section 2 above).  

When considering offering, accepting or providing gifts, hospitality or entertainment all employees must ensure that they shall:  

• Be in good faith, occasional, appropriate, reasonable and proportionate  
• Constitute a normal business courtesy (such as paying for a meal or shared taxi)  
• Comply with any applicable laws, including those which may apply to any relevant foreign public officials  
• Not be possible of reasonably being perceived in any way as a bribe and  
• Not be in cash  

 By way of guidance:  

• Customary gifts or modest Christmas gifts may be accepted provided the value of such gifts does not exceed £50 per annum from any one source  
• Reasonable entertainment in restaurants, theatres and at sporting or cultural events is allowed provided that it is not excessive and is not repeated on frequent occasions.  

8.0 Register of Hospitality Received  

As from the 1st July 2011 every officer, director and employee is required to declare any benefits they receive that they estimate would have cost the provider more than £10 per person to provide. The declaration should be made by completing this form and must state, the employee’s name, the name of the individual that provided the hospitality and the organisation they work for, a short description of the hospitality received and an estimate of the cost of the hospitality received.  

9.0 Associated Persons  

Lucion Group will only contract with Associated Persons and engage with business partners who demonstrate at all times business integrity and who practice ethical conduct which meets the standards set out in this Policy and all applicable laws and regulations.  

10.0 Compliance Monitoring  

Compliance with this Policy by all relevant officers and employees and all Associated Persons will be reviewed periodically.  

Additionally, employees are provided with an annual Impartiality Questionnaire which is used to declare whether their potential risk to impartiality through their relationships or business contacts. Where a risk is identified, this is assessed and changes to personnel or contract will be made as appropriate.  

11.0 Training  

Lucion Group officers and employees (whether permanent or temporary) in commercial or customer or supply chain facing positions will be given anti bribery training.   

12.0 Obligation to report your concerns  

If you have any concerns that anyone within Lucion Group or any Associated Person is offering, promising or paying bribes to anyone or requesting, agreeing to accept or receiving bribes, please raise them with your line manager, the Group HR Director or the CEO in line with our Whistleblowing Policy.  

13.0 Breaching the Anti-bribery Laws and This Policy  

There are severe penalties for breach of the UK Bribery Act these being an unlimited fine and/or imprisonment for up to 10 years. As importantly, failure to comply with the new legislation will cause considerable damage to the good name and reputation of Lucion Group. Lucion Group considers a breach of this Policy as a serious offence. Any violation will result in disciplinary action up to and including dismissal of an individual in appropriate circumstances. The business relationship with Associated Persons who violate this Policy may also be terminated.  

Lucion Group officers and employees must therefore ensure that they are familiar with the content of this Policy and adhere to it at all times. If you have any questions as to the requirements or scope of this Policy, guidance should be sought from either your line manager, the Group HR Director or the CEO.  

Ross Boulton

Chief Technical Officer 

11th June 2024