1. Introduction to the standard
1.1 This Anti-Bribery and Corruption Standard (the “Standard”) is intended to ensure that all subsidiaries of Renew Holdings plc (“Renew”), their directors, managers, employees and third party service providers comply with anti-bribery laws, in particular the Bribery Act 2010.
1.2 Individuals face up to 10 years imprisonment and/or an unlimited fine if they engage in bribery and Renew or its subsidiary business commit a criminal offence if they do not take steps to prevent bribery by its associated persons.
1.3 This Standard applies to all subsidiaries of Renew. The directors of all subsidiaries are required to ensure that the requirements set by this Standard are implemented and followed by their respective businesses.
1.4 This Standard does not remove the requirement for each Renew subsidiary to have in place its own anti-bribery and corruption compliance programme.
1.5 All Managing Directors of each Renew subsidiary is required to provide the Company Secretary of Renew with an annual Anti-Bribery compliance confirmation.
2. Bribery Act 2010
2.1 The Bribery Act 2010 makes it an offence:
2.1.1 To bribe another person: to offer, promise or giving of a financial or other advantage with the intention of inducing another person to do something improper in carrying out work or performing function, or to reward that person for doing so;
2.1.2 To be bribed: to request, agree to receive or accept a financial or other advantage intending that, as a result of the bribe, work or a function will be carried out improperly as a result.
2.1.3 It is also an offence to offer, promise or give a thing of value to someone (or to request or receive) when it is known or believed that acceptance of that thing is in itself improper, for example because the relevant rules of that persons' employment prohibit them from accepting gifts in the context of their employment.
2.2 Businesses can also be criminally liable for failing to prevent bribery by those that provide services for or on its behalf. This can include its subsidiaries, joint ventures, directors, employees, agents, and other third party service providers.
3. Requirements of subsidiary business
3.1 Each subsidiary of Renew is required to have in place:
3.1.1 An anti-bribery and corruption policy;
3.1.2 Board oversight of the business’ anti-bribery and corruption compliance programme;
3.1.3 A regular programme of anti-bribery risk assessments;
3.1.4 A system of risk based due diligence for suppliers and other third party service providers;
3.1.5 A policy and clearly defined rules in relation to:
(a) Gifts and hospitality;
(b) Political contributions;
(c) Charitable donations;
(d) Sponsorships; and
(e) Conflicts of interest.
3.1.6 Clear systems for employees or third parties to report compliance concerns (including the option for anonymous reporting);
3.1.7 A programme of regular anti-bribery and corruption training for all directors and employees; and
3.1.8 A system of monitoring the effectiveness and adequacy of its anti-bribery compliance programme.
