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Anti-Corruption and Bribery Policy

1. About our policy

1.1 It is our - Mighty's - policy to conduct all of our business in an honest, open and ethical way. We take a zero-tolerance approach to corruption and bribery and we are committed to acting in a professional, fair way and ensuring that we act with integrity in all our business dealings and relationships.

1.2 Any Mighty employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.

1.3 This policy does not form part of any employee's contract of employment and we may amend it at any time. It will be reviewed regularly.

1.4 We may also terminate our relationship with other individuals and/or organisations that are working on our behalf if they breach any part of this policy.

2. Who must comply with our policy?

This policy applies to all persons working for us (or any of Mighty's group companies) or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, distributors,  seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, business partners, or any other person associated with us wherever located.

3. What is bribery?

3.1 Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

3.2 Bribery includes offering, promising, giving, accepting or seeking a bribe.

3.3 All forms of bribery are strictly forbidden. If you are unsure about whether a particular act constitutes bribery, you must raise it with your line manager - in the case of a non-employee, please raise is with your Mighty contact.

3.4 Specifically, you must not:
(a) give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
(b) accept any offer from a third-party that you know, suspect or have reason to believe is made with the expectation that we will provide a business advantage for them or anyone else; and
(c) give or offer any payment (sometimes referred to as a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.

4. Hospitality and Gifts

4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as gift certificates or vouchers), or be given in secret. Gifts must be given in our name, not your name.

4.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

5. Records

5.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

5.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.

6. Raising concerns

If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager (or Mighty contact, if applicable) as soon as possible.

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