Global Anti-Bribery and Corruption Policy (ABC)

last updated: 07 June 2021

Introduction 

TeamKinetic has a zero-tolerance policy to bribery and corruption. This zero-tolerance approach is set out in the anti-bribery and corruption (“ABC”) policies, procedures and guidances which collectively provide a comprehensive set of standards that all of us, without exception, are required to comply with. High standards of ethical behaviour and compliance with laws and regulations are essential to protecting the reputation and long-term success of our business. 

Any incidents of bribery and corruption involving, or relating to, the Company will damage our reputation. All employees have a personal responsibility for protecting our reputation and living up to our values of being trusted to deliver excellence. Breaches of the ABC Policies are not acceptable and may result in disciplinary action up to and including dismissal. This Global Anti-Bribery and Corruption Policy (“Policy”) is mandatory and applies to all employees of TeamKinetic, its subsidiaries and joint ventures which TeamKinetic controls (“TeamKinetic” or “Company” or “employees”). TeamKinetic employees who are directors on Boards of non-controlled joint ventures should encourage the joint venture to adopt this Policy as a model or use a similar policy. The ABC Policies set a minimum standard that must be followed. Where local laws, regulations or rules impose a higher standard, that higher standard must be followed.

Common terms 

ABC Laws and Regulations 

The UK Bribery Act, the US Foreign Corrupt Practices Act, any legislation implementing the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the Proceeds Of Crime Act, the AntiTerrorism Act and other similar laws and regulations in the countries where we do business. 

ABC Policies 

The Company policies, including this Policy, procedures and guidance dealing with ABC issues, which collectively provide a comprehensive set of standards with which TeamKinetic and its employees are required to comply. The ABC Policies are listed on our website. 

Bribe 

Anything of value including any financial or other advantage given, offered, requested or received in order to improperly influence any act, inaction or decision of any person, including any government official or any director, officer, employee, agent or representative of any commercial organisation or of any private individual.

Global Anti-Bribery and Corruption Policy 

1.1. Policy 

1.1.1 TeamKinetic has a zero-tolerance approach to bribery and corruption. Employees must at all times comply with the ABC Policies and the ABC Laws and Regulations. 

1.1.2 The ABC Policies set out the minimum requirements and procedural steps that all employees must follow in order to comply with this Policy. Each sector and function may impose additional requirements but the requirements, steps and standards contained in the ABC Policies must not be reduced. 

1.2. All employees You must: 

1.2.1 not give or offer, directly or indirectly, anything that either is or could reasonably be viewed to be a Bribe; 

1.2.2 not request or accept, directly or indirectly, anything that is or could reasonably be viewed to be a Bribe; 

1.2.3 familiarise yourself with the ABC Policies and act in accordance with them; and 

1.2.4 report as soon as possible if you know or suspect a breach of any ABC Policy by you or by another person. Reports should be made to a member of the senior management. 

Conflict of Interest

In accordance with section our Code of Conduct we seek to avoid Conflicts of Interest but, where they occur, we manage them by making appropriate reports to our management and abiding by the suggested actions to help resolve or manage the Conflict of Interest. 

This Global Conflict of Interest Policy (“Policy”) is mandatory and applies to all employees and representatives of TeamKinetic  and its wholly owned subsidiaries (“TeamKinetic ” or “Company” or “employees”). 

A TeamKinetic  employee who is a director on a Board of a joint venture should encourage the joint venture to adopt this Policy as a model or use a similar policy which meets similar standards. 

This Policy and the other Anti-Bribery and Corruption Policies (“ABC Policies”) set a minimum standard that must be followed. Where local laws, regulations or rules impose a higher standard, that higher standard must be followed. Breaches of the ABC Policies are not acceptable and may result in disciplinary action up to and including dismissal. 

Common terms 

Conflict of Interest: any relationship, (whether personal or professional), influence or activity that may impair or appear to impair the ability of employees to: a. make fair and objective decisions when performing their jobs; or b. act in the best interests of the Company. Examples are available in the TeamKinetic  Global Code of Conduct or the Conflict of Interest Guidance at the end of this Policy. 

Insider Trading: making investment decisions based on non-public information that should be confidential. 

Conflict of Interest Report: any written report detailing a Conflict of Interest which can be made in a written format agreed with your Line Manager. The written report must include: a. the nature of the Conflict of Interest; and b. steps taken to manage, resolve, or remove the Conflict of Interest.

1.1 All employees You must: 

1.1.1 seek to avoid any relationship, influence or activity that will impair, or appear to impair, your ability to do your job or make fair and objective decisions when performing your job, or that is not in the best interests of TeamKinetic.

Where such a situation cannot be avoided you must: a. report the situation promptly to your Line Manager; 

b. take steps to remove or mitigate the Conflict of Interest; 

c. carry out any Conflict of Interest resolution or termination activities your Line Manager recommends; and 

d. complete a Conflict of Interest Report; 

1.1.2 not engage in, facilitate or encourage Insider Trading; 

1.1.3 report as soon as possible if you know or suspect a breach of this or any other ABC Policy by you or by another person. Reports should be made to a member of the Senior management.