Anti Bribery & Corruption

ASG Group are committed to applying high standards of honesty and integrity consistently across all the ASG Group’s business dealings wherever they might take place.

The Company’s bribery and corruption policy applies to all employees. The Company expects its business partners and service providers, irrespective of their location or function, to act with integrity and without thought or actions involving bribery and/or corruption.

ASG Group’s bribery and corruption policy requires all employees:

1. Not to offer or make any kind of bribe or other unorthodox inducement to anyone.

2. Not to solicit opportunities by offering any kind of bribe or other unorthodox or inducement to potential customers.

3. Not to accept any kind of bribe or other unorthodox inducement that would not be authorised or ratified by ASG Group in the ordinary course of business.

4. To refuse any kind of bribe or other unorthodox inducement and to do so in a manner that is not open to misunderstanding or that gives rise to false expectations; and to report any offers of any kind of bribes or other unorthodox inducements.

5. Not to make facilitation payments (i.e. payments to businesses or individuals to secure or expedite the performance of a routine or necessary action to which the person making the facilitation payment has a legal or other entitlement.)

6. To report any breaches of ASG Group’s bribery and corruption policy. Employees can report concerns in confidence to any member of the Board or via a confidential Ethics Hotline without fear of reprisals. Any reports raised will be taken seriously by the Board and no one will be discriminated against in any way as a result of reporting a concern in good faith.

Any breach of ASG Group’s bribery and corruption policy will be considered as grounds for disciplinary action, which may include dismissal.

Note: Hospitality or promotional expenditure which is reasonable, proportionate and made in good faith is an established and important part of doing business. The Bribery Act 2010 does not seek to penalise such activity.

Hospitality and promotional expenditure could however form the basis of offences under the Act. The more lavish the hospitality or expenditure (beyond what may be reasonable standards in the particular circumstances), the greater will be the inference that it is intended to encourage or reward “improper performance” or “influence an official”. Other factors might include that the hospitality or expenditure was not clearly connected with legitimate business activity or was concealed. (“Guidance of the Director of the Serious Fraud Squad and the Director of Public Prosecutions”).

Revised September 2024