Rumpus Limited (“the Company”) is committed to the practice of responsible corporate behaviour.

Through its business practices, the Company seeks to protect and promote the human rights and basic freedoms of all its employees and agents.

Further, the Company is committed to protecting the rights of all of those whose work contributes to the success of the Company, including those employees and agents of suppliers to the Company.

The Company is also committed to eliminating bribery and corruption. It is essential that all employees and persons associated with the Company adhere to this policy and abstain from giving or receiving bribes of any form.

This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy.

Human Rights

The Company is vehemently opposed to the use of slavery in all forms; cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion.

The Company will ensure that all of its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998.

The Company will not enter into any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breaches the human rights of those affected by the organisation’s activities.

Workers’ Rights

The Company is committed to complying with all relevant employment legislation and regulations. The Company regards such regulations and legislation as the minimum rather than the recommended standard.

No worker should be discriminated against on the basis of age, gender, race, sexual orientation, religion or beliefs, gender reassignment, marital status or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal pay for equal work.

No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment as a result of joining, or failing to join, any such organisation.

Workers should be aware of the terms and conditions of their employment or engagement from the outset. In particular, workers must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be allowed such annual leave, sick leave, maternity/paternity leave and such other leave as is granted by legislation as a minimum.

The Company does not accept any corporal punishment, harassment in any form, or bullying in any form.

Environmental Issues

The Company is committed to keeping the environmental impact of its activities to a minimum and has established an Environmental Policy in order to help achieve this aim. Copies of the Environmental Policy are available within our Employee Handbook.

As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction it may be operating.

Conflicts of Interest

The Company holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers and employees. Conflicts of interest potentially undermine the relationship of the Company with its partners.

In order to help preserve and strengthen these relationships the Company has developed a Corporate Hospitality and Gifts Policy, which provides rules and guidelines concerning the conduct of its officers and employees aimed at minimising the possibility of conflicts of interest and at avoiding risks associated with bribery and corruption. Copies of the Corporate Hospitality and Gifts Policy are available within the employee handbook.

All officers, employees and representatives of the Company are expected to act honestly and within the law.

Information and Confidentiality

Information received by employees, contractors or agents of the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given.

The Company will at all times ensure that it complies with all applicable requirements of the Data Protection Legislation. “Data Protection Legislation” means (1) unless and until General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) is no longer directly applicable in the UK, the GDPR and any national implementing laws, regulations, and secondary legislation (as amended from time to time) in the UK and subsequently (2) any legislation which succeeds the GDPR.

Suppliers and Partners

The Company expects all suppliers and partners to work towards and uphold similar ethical and moral standards.

The Company will investigate the ethical record of potential new suppliers before entering into any agreement. Further, the Company reserves the right to request information from suppliers regarding the production and sources of goods supplied.

The Company reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who is found to have acted in contravention of the spirit or principles of this Ethical Policy.

Bribery and Corruption

The Company is fundamentally opposed to any acts of bribery and the making of facilitation payments as defined by the Bribery Act 2010.

Employees and any other persons associated with the Company such as agents, subsidiaries and business partners are not permitted to either offer or receive any type of bribe and/or facilitation payment.

All employees are encouraged to report any suspicion of corruption or bribery within the Company in accordance with the Whistleblowing Policy available within the Employee Handbook.

Should any employee or associated person be in doubt when receiving or issuing gifts and hospitality, he/she must refer to the Gift and Hospitality Policy available within the Employee Handbook.

The Company uses its reasonable endeavours to implement the guiding principles on bribery management that are published, from time to time, by the Secretary of State in accordance with Section 9 of the Bribery Act 2010.

If an employee or associated person is found guilty of giving or receiving a bribe, he/she will be personally criminally liable and may be subject to disciplinary action.

Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.

Hospitality and Gifts Policy

The Company recognises that trust and confidence in the propriety of its activities are essential to its continuing success and growth. To foster the trust and confidence that clients, suppliers, workers and the community, in general, have in the Company, it is important that the Company, its employees and agents behave, and are seen to behave, appropriately and honestly at all times.

This Hospitality and Gifts Policy aims to:

• Protect the reputation of the Company;
• Protect employees from accusations of impropriety;
• Ensure that all clients and suppliers are dealt with on an equal basis;
• Avoid any potential conflicts between employees’ private interests and professional duties;
• Instil a strong anti-corruption culture in the Company and put in place a gift and hospitality monitoring process to further compliance with the Bribery Act 2010.

Employees are advised that notwithstanding anything contained herein, where there is any doubt over the permissibility or propriety of accepting a gift or hospitality offer they should decline that offer. Nothing should be accepted which would bring the Company into disrepute.

This policy applies to the Company and to any associated persons as defined by the Bribery Act 2010.

Receiving Gifts

Save for gifts of low value and which are mere tokens (such as promotional pens, calendars and stationery), excluding money, employees of the Company are not permitted to accept any gifts from customers, suppliers or other third parties involved with the Company.

The Company recognises that there may be exceptional instances when refusing a gift will cause significant offence or embarrassment. In such instances, the gift may be accepted and subsequently donated to a charity of the Company’s choice.

Where practicable any employee minded to accept a gift should first seek approval from their manager. If it is not practicable to gain prior approval, the accepting employee should inform their manager as soon as possible after receiving the gift.

Hospitality

“Corporate Hospitality”, for the purposes of this policy, is any form of accommodation, entertainment or other hospitality provided for an employee of the Company by a third party and which is extended to the employee solely or significantly due to his position as a representative of the Company.  This excludes the classes of hospitality particularised below.

For the purposes of this policy and for the sake of clarity, the following are not normally considered Corporate Hospitality and will not require any approval prior to acceptance:

• Normal working lunches or refreshments provided during a business visit;
• Hospitality extended to employees attending a Company approved seminar, conference or other external event, provided that such hospitality is extended to all who are in attendance;
• Free seminars, talks or workshops, provided that they are free to all in attendance and are not provided solely for employees of the Company.

All employees are required to obtain approval before accepting any form of Corporate Hospitality which is offered to them. Approval must be sought from their manager or, where the value of the Corporate Hospitality is likely to be over £50, from a Director.

An accurate record must be kept of all Corporate Hospitality offered to the Company or employees of the Company for entry on the Register. Any employee offered any form of Corporate Hospitality must record, as soon as is reasonably practicable:

• A description of the hospitality offered;
• An estimation of the likely value of the hospitality;
• Whether it was rejected or accepted;
• If accepted, why it was accepted; and
• From whom prior approval was obtained.

Breach of this Policy

Compliance with this policy is essential to the protection of the Company’s reputation and that of its employees. Any employee or an associate person who is found to have acted in contravention of this policy or its principles may be subject to disciplinary action, including summary dismissal where the breach amount to gross misconduct.

Any employee or any associated person (as defined by Section 8 of the Bribery Act 2010) found giving or receiving bribes or bribing a foreign official will face criminal charges under the provisions of the Bribery Act 2010. Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.

Anti-Bribery Policy

The Company is committed to ensuring that all our commercial dealings meet the highest professional standards. It would never be acceptable for anyone to accept or offer bribes in any business transaction.

Bribes may come in a variety of forms such as corporate hospitality, charitable donations and personal gifts, as well as money. Any employee being offered any of these must report this to the Director who will advise how to manage the situation. Breaches of this rule will result in disciplinary action up to and including dismissal.

Introduction

Bribery and corruption remain major issues in world trade, despite the many dedicated efforts to prevent them. Our legal obligations are primarily governed by the Bribery Act 2010. That Act affects us, as a UK company, if bribery occurs anywhere in our business.

Corruption and bribery are very damaging to the societies in which they occur. They divert money and other resources from those who need them most and hinder economic and social development. They damage business, not least by increasing the cost of goods and services.

The Company runs its business with integrity and in an honest and ethical manner. All of us must work together to ensure that our business remains untainted by bribery or corruption. This policy is a crucial element of that effort. This policy has the full support of the Company’s board. However, the policy needs the full support of you, the Company’s staff, to make it work.

This policy sets out the steps all of us must take to prevent bribery and corruption in the business to comply with relevant legislation and the Company’s requirements.

What are bribery and corruption?

A ‘bribe’ is a financial or other advantage offered, promised, requested or given to induce a person to perform a relevant function or activity improperly, or to reward them for doing so. In this context, a ‘financial or other advantage’ is likely to include cash or cash equivalent, gifts, hospitality and entertainment, services, loans, preferential treatment in a tendering process, discounts etc. The timing of the bribe is irrelevant and payments made after the relevant event will still be caught, as will bribes that are given or received unknowingly. It is not necessary for the individual or organisation actually to receive any benefit as a result of the bribe.

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

‘Corruption’ is the misuse of office or power for private gain.

All forms of bribery and corruption are strictly prohibited. If any member of staff is unsure about whether a particular act constitutes bribery, they should raise it with their Manager.

Staff must not:

• give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received, or to reward any business received;
• accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else; and
• give or offer any payment (sometimes known as a ‘facilitation payment’) to a government official in any country to facilitate or speed up a routine or necessary procedure.

No person must threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

Who might be involved in bribery and in what circumstances?

Bribery and corruption might be committed by:

• the Company’s employees, officers or directors;
• anyone they authorise to do things on their behalf;
• the Company’s representatives and other third parties who act on its behalf;
• the Company’s suppliers; and
• even the Company’s customers (for example, a customer might try to induce one of the Company’s employees to give that customer more favourable terms).

Bribery can occur in both the public and private sectors. The person receiving the bribe is usually in a position to influence the award or the progress of business, often a government or other public official.

The legal position on bribery

Bribery and corruption are criminal offences in most countries where the Company does business. UK-incorporated companies, including the Company, are subject to the Bribery Act 2010. Under the Act, it is illegal:

• to pay or offer to pay a bribe;
• to receive or agree to receive a bribe;
• to bribe a foreign public official; and/or
• for a commercial organisation, to fail to have adequate procedures in place to prevent bribery.

It does not matter whether the bribery occurs in the UK or abroad. A corrupt act committed abroad may well result in a prosecution in the UK.

The Company’s position on bribery

Involvement in bribery and corruption exposes the Company to a criminal offence. It will also damage our reputation and the confidence of our clients, customers, suppliers and business partners.

The Company’s position is simple: the Company conducts its business to the highest legal and ethical standards. The Company will not be a party to corruption or bribery in any form. Such acts would damage the Company’s reputation and expose the Company, and its employees and representatives, to the risk of fines and imprisonment.

The Company takes a zero-tolerance approach to bribery and corruption by its people and its third-party representatives.

Bribery may be more widespread in some countries, and business sectors, than in others. In some cases, you may be told that unless the Company pays bribes it will not win business or be able to complete contracts. That does not matter.

This ethical stance is good for our business and is non-negotiable.

What are the indicators of bribery and corruption?

Common indicators of bribery and corruption include those listed below but there may well be others. Examples include:

• Payments are for abnormal amounts or purposes (eg ‘commission’), or made in an unusual way (eg what would normally be a single payment is made in stages, through a bank account never previously used, and/or in a currency or via a country which has no connection with the transaction);
• Process is bypassed for approval or sign-off of terms or submission of tender documents, payments, or other commercial matters; those whose job it is to monitor commercial processes may be prevented from or hindered in doing so;
• Individuals are secretive about certain matters or relationships and/or insist on dealing with particular customers or contacts personally; they may make trips at short notice without explanation, or have a more lavish lifestyle than expected;
• Decisions are taken for which there is no clear rationale; and/or
• Records are incomplete or missing.

Your responsibility

Everyone in the Company is responsible:

• for reading and being aware of the contents of this policy and complying with it;
• for keeping full and accurate records of all cases where bribery is suspected; and
• for reporting cases where the individual knows or has a reasonable suspicion, that bribery has occurred or is likely to occur in the business.

We will not penalise anyone who loses business as a result of not engaging in bribery or corruption.

Corporate hospitality

Corporate hospitality that is proportionate and offered as part of building business relationships that are open and transparent and approved by a Director is permitted by this policy. Please see our corporate hospitality policy within the employee handbook for more information.

What to do if you think something is wrong

Each of us has a responsibility to speak out if we discover anything corrupt or otherwise improper occurring in relation to the business. The Company cannot maintain its integrity unless we do that. If you are offered a bribe or are asked to make one, or if you discover or suspect that any bribery or corruption has occurred or may occur, you must tell your Manager.

You must make your report as soon as reasonably practicable. You may be required to explain any delays.

Compliance with this policy

The Company takes compliance with this policy very seriously. Failure to comply puts both individuals and the Company at risk.

Individuals may commit a criminal offence if they fail to comply with this policy. The criminal law relating to bribery and corruption carries severe penalties.

Because of the importance of this policy, failure to comply with any requirement of it may lead to disciplinary action under our procedures, and this action may result in dismissal for gross misconduct.

Purchasing and Commissioning

The overriding principle is that all dealings with current and potential suppliers and service users are seen to be properly handled, with the application of high standards of objectivity, integrity and fairness.

The Company is involved in commissioning work and in tenders for contracts with other organisations. Unless the Managing Director has given specific permission, employees must not provide information, support or assistance to any Company or organisation tendering for work with them that would in any way enhance their chances of being successful in their bid.

Corporate Social Responsibility

Corporate Social Responsibility (CSR) is the concept whereby The Company integrates social and environmental concerns into their business operations and into their interaction with their stakeholders voluntarily. The Company is committed to adopting best practices in this area.

The Company is fully committed to the principle of CSR and intends that CSR should become embedded, where appropriate, into its policies and practices, to the benefit of staff, people we support, as well as the wider community.

The Company aims to be recognised as an organisation that is transparent and ethical in all its dealings as well as making a positive contribution to the community in which it operates. It is committed to the following core values in all aspects of its work, including the fulfilment of its social responsibility:

• Clear direction and strong leadership
• Customer focus
• Respect for people
• Open communication
• Working to deliver the best value
• Openness and transparency
• Equality
• Probity
• Development of positive working relationships with others
• Commitment to the highest ethical standards of service; and
• Valuing and harnessing the diversity of The Company staff.

CSR Strategies

The Company will seek to achieve corporate and social objectives by focusing on five strategic areas:

• Equal Opportunities – maintaining and promoting our commitment to the fulfilment of and the promotion of equal opportunities.
• Good Relations – The Company has developed and maintained good relations with other
• providers and professionals.
• Workplace – addressing the needs and aspirations of staff through the continuing development of diversity, work-life balance and health and well-being and initiatives.
• Community Impact – encouraging and assisting staff to greater involvement in team/individual projects in support of the wider community.
• Environment – further developing environmental management practices that minimise waste and maximise efficiencies.

Purchasing Principles

Adopting an environmentally friendly purchasing policy has 2 objectives:

• To ensure the Company purchases products which minimise damage to the environment;
• To persuade suppliers to offer products which minimise damage to the environment.

It is the Policy of the Company to purchase products and services which minimise damage to the environment and to inform suppliers of our policy.

Suggestions for implementing this policy include:

Purchase of products made from recycled materials or derived from sustainable sources including:

• All paper products
• Wooden Furniture

Purchase of products which minimise environmental pollution or damage including:

• Biodegradable cleaning products;
• Organic food;
• Avoiding genetically-modified food products;
• Avoiding unnecessary packaging;
• Opting for local producers and suppliers (reducing transportation).

The purpose of this policy is not to make perfect decisions, but to create a mindset that thinks about the issues and tries to make informed decisions.  It is recognised that price is also a factor and many ‘environmentally friendly goods and services are more expensive than their industrialised counterparts.  Some are simply not up to the job and should therefore be avoided.