Policy and Purpose Statement

The purpose of this Policy is to provide a clear set of guidelines to ensure that we conduct our activities in an ethical and appropriate manner, and comply with the laws and regulations of every jurisdiction where we operate. It is designed to help you recognise and handle risk situations that could lead to bribery or corruption concerns.

This policy applies to all our employees regardless of employment agreement or position.

What is a bribe?

A bribe is an inducement or reward of anything of value that is offered, promised, given or accepted in order to gain any unfair business or personal advantage.

Bribes can take main forms, including but not limited to:

• Gifts (of any value).
• Entertainment and Hospitality (lavish meals, alcohol, hotel accommodations, shows, sporting events or other high-price events).
• Travel (plane tickets, ticket upgrades or trip expenses).
• Facilitation Payments
• Kickbacks
• Favourable Contracts
• Business Opportunities
• Sponsorships
• Charitable or Political Contributions
• Stock Options

Bribes can be provided or received in many ways, including:

• Directly: a customer requesting an expensive dinner, drinks, gift or cash payment as a necessary precondition to discuss potential business for APG (same case applied if somebody did the same on behalf of APG).
• Indirectly: a government official asking for a cash payment through a third part (i.e. consultant or agent) before granting APG the right to do business in a certain area or a specific way.
• Kickbacks: an agent offering commission on any profit they gain from selling APG’s services in exchange of APG choosing them over other agents, or a customer requesting commission on APG’s sales in exchange of ensuring APG is elevated over other suppliers (same case applies if somebody did the same on behalf of APG).

APG will not countenance behaviour of this nature. It is not tolerated and will amount to gross misconduct if carried out which leads to summary dismissal. Always be vigilant.

We are able to offer hospitality to clients as long as it is not designed to coerce them into doing something that we want that will gain an advantage for us.

If anyone offers you a gift, this should be reported to your manager, no matter the value (including gifts shared around public holidays).

Bribery can also be in less direct monetary forms, for example client offers to pay more than those rates or offers a large sum as an advance when you have not yet requested money on account. This could be an attempted bribe.

Never accept payment in cash without manager approval which is unlikely to be given.

Always seek manager approval if the client wishes to pay in kind i.e. in ways other than money as the value cannot be quantified and could be seen as a bribe if clearly above charge out charging rates in value when applied.

Always seek manager approval before accepting work from a client.

Think carefully about where the client comes from as it may be from a company where corruption is prevalent. Carry out internet research if you are unsure – use government departments such as UK Trade and Investment or UK Diplomatic Posts. If in doubt, report this to your Manager.

The risks of bribery at APG are considered high because we do work with clients abroad where bribery is prevalent.. We must be vigilant in this regard particularly where we are considering taking on a client from a region where we have not dealt with before .If you need services abroad and are asked to pay something for someone’s trouble or to facilitate a service which may not otherwise be available be on instant alert. Ask if this is an official charge and if a price list is available and if in doubt seek manager approval.

Steps to take if you believe you have received a bribe & Reporting Concerns

If you suspect you have received a bribe of any kind as noted in this policy, you should immediately inform your Manager, the HR Department, or the Senior Management Team. Even if you lack complete information or are reluctant to get involved, it is crucial to voice your concerns. If you prefer to report anonymously, you can do so using the whistleblower email (Whistleblowing@apgecommerce.com) or the suggestion box form (located on BambooHR).

As employees, it is our duty to report any potential misconduct. Doing so not only helps to prevent future violations but also safeguards employees, directors, and the Company from legal issues and reputational harm.