Anti-Bribery and Corruption Policy

As part of the UK Government’s commitment to eradicating bribery, the Bribery Act 2010 came into force on 1 July 2011.

Hydraulics Online Ltd is committed to conducting business fairly, ethically and within the law.

We run our business honestly and will not tolerate bribery or corruption in any of our dealings and relationships or from any of our colleagues or third-parties. We have systems in place to prevent bribery and corruption and require all our employees and associated persons to act and make decisions in line with our Anti-Corruption and Anti-Bribery Policy and Procedures.

The purpose of this Policy is to set out the responsibilities of every person with whom Hydraulics Online Ltd is associated, to observe and uphold our zero-tolerance position to bribery and corruption.

The term “associated person” used in this Policy includes, but is not limited to, any individual or organisation that Hydraulics Online Ltd comes into contact within the course of its business including: actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, government and public bodies, their advisers, representatives and officials, politicians and political parties.

This Policy applies to all Hydraulics Online Ltd business dealings and transactions in all countries in which we operate. There are no exceptions to this Policy.

Hydraulics Online Ltd does not tolerate any form of bribery or corruption. Violation of this Policy may be grounds for dismissal, termination of contract, prosecution or additional criminal or civil sanctions. If local laws, codes of conduct, or other regulations in another country or region are more restrictive on this subject, or require government approval of the transaction, then the more restrictive requirements must be complied with.

Bribery is any activity that is a criminal offence under the Bribery Act 2010. There are four offences (the “Bribery Act Offences”):

• bribing another person (section 1);
• being bribed (section 2);
• bribing a foreign public official (section 6); and
• failure of a commercial organisation to prevent bribery (section 7).

Bribing another person (Section 1): Where a person (P) offers, promises or gives a financial or other advantage to another person (R), and P intends the advantage to induce R to perform a relevant function or activity improperly, P commits an offence. A relevant function or activity means one that is:

• connected with business;
• performed in employment; or
• performed on behalf of another body,

that should be performed in good faith, or impartially, and/or by a person in a position of trust.

Being bribed (Section 2): Where a person requests, agrees to receive or accepts a financial or other advantage intending that a relevant function or activity is performed improperly he commits an offence.

Bribing a foreign public official (section 6): A person (P) who bribes a foreign public official commits an offence if it is P’s intention to:

• influence him in his capacity as a foreign public official; and
• obtain or retain business or an advantage in the conduct of business.

Failure of a commercial organisation to prevent bribery (section 7): A relevant commercial organisation is guilty of an offence if a person associated with it bribes another person intending to obtain or retain business for the organisation, or an advantage in the conduct of the organisation’s business.

All those associated with Hydraulics Online Ltd must not engage in any activity that might lead to, or suggest, a conflict of interest with the business of Hydraulics Online Ltd.

The offering, or giving, of gifts, hospitality and entertainment must:

• not be given/received with the intention of influencing a third party to obtain or retain business or a business advantage, to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
• not constitute an offence under the Bribery Act;
• comply with local law;
• be given at corporate level not an individual level;
• not include cash or a cash equivalent;
• be appropriate, reasonable, proportionate, given in good faith at an appropriate time;
• be given openly; and
• not be offered to, or accepted from, government officials, representatives, politicians or political parties without the express prior approval of a member of the Hydraulics Online Ltd Board of Directors.

Hydraulics Online Ltd does not make, and will not accept, facilitation payments or “kickbacks” of any kind.

Hydraulics Online Ltd recognises that in some countries facilitation payments are permitted in law. Hydraulics Online Ltd is subject to the provisions preventing facilitation payments in the UK regardless of whether local law permits facilitation payments. They are therefore completely prohibited by Hydraulics Online Ltd regardless of country. You must not engage in any activity that might lead to, or suggest, that a facilitation payment or kickback will be made, or accepted, by Hydraulics Online Ltd.

Hydraulics Online Ltd does not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices. No donation of any kind must be offered, or made, on behalf of Hydraulics Online Ltd without the express consent of a member of the Board of Directors of Hydraulics Online Ltd.

You must ensure that you have read and understand the terms of this Policy.

You must always comply with its terms when acting on behalf of Hydraulics Online Ltd. You must inform Hydraulics Online Ltd of the details of any third party or other engaged by you on behalf of Hydraulics Online Ltd and you must ensure that they agree to be bound by, and comply with, the terms of this Policy.

If you employ staff who act as agent on behalf of Hydraulics Online Ltd or engage others to do so (where permitted) you must ensure that those persons are fully aware of the terms of this document, and where necessary ensure training is provided. Under no circumstances may you offer gifts (cash or otherwise) to any of our colleagues. Any such offer shall be refused. Offers of corporate hospitality are subject to the provisions of paragraph 4 above and may only be accepted by colleagues if they have obtained the appropriate authority in advance. Colleagues must declare any offers received.

You must ensure that you retain documentation identifying and relating to any third party or other engaged by you on behalf of Hydraulics Online Ltd.

This Policy will be communicated to our suppliers, contractors, agents and business partners who will be asked to review the Policy and agree to abide by its terms.

Employees, suppliers, customers, third-parties or agents can make contact confidentially with Hydraulics Online Ltd by emailing:  feedback@hydraulicsonline.com or by writing to: The Board of Directors c/o The Company Secretary Hydraulics Online Ltd, 2-3 Townend Farm, Audley Road, Alsager, Cheshire, UK, ST72QR.

Anyone raising a concern in good faith will not be criticised or penalised in any way even if it is shown, after investigation, that they were mistaken. Any form of reprisal or victimisation against anyone who has raised a genuinely held concern is forbidden and will not be tolerated and itself will be treated as a disciplinary matter.