MODERN SLAVERY POLICY

1. What does your policy cover?
a. This anti-bribery policy exists to set out the responsibilities of Brave Bear Marketing and those
who work for us in regard to observing and upholding our zero-tolerance position on bribery
and corruption.
b. It also exists to act as a source of information and guidance for those working for Brave Bear
Marketing. It helps them recognise and deal with bribery and corruption issues, as well as
understand their responsibilities.


2. Policy statement
a. Brave Bear Marketing is committed to conducting business in an ethical and honest manner
and is committed to implementing and enforcing systems that ensure bribery is prevented.
Brave Bear Marketing has zero-tolerance for bribery and corrupt activities. We are committed
to acting professionally, fairly, and with integrity in all business dealings and relationships,
wherever in the country we operate.
b. Brave Bear Marketing will constantly uphold all laws relating to anti-bribery and corruption in all
the jurisdictions in which we operate. We are bound by the laws of the UK, including the
Bribery Act 2010, in regard to our conduct both at home and abroad.
c. Brave Bear Marketing recognises that bribery and corruption are punishable by up to ten years
of imprisonment and a fine. If our company is discovered to have taken part incorrupt activities,
we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and
face serious damage to our reputation. It is with this in mind that we commit to preventing
bribery and corruption in our business and take our legal responsibilities seriously.


3. Who is covered by the policy?
a. This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent),
consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff,
volunteers, interns, agents, sponsors, or any other person or persons associated with us
(including third parties), or any of our subsidiaries or their employees, no matter where they are
located (within or outside of the UK). The policy also applies to Officers, Trustees, Board,
and/or Committee members at any level.
b. In the context of this policy, third-party refers to any individual or organisation our company
meets and works with. It refers to actual and potential clients, customers, suppliers,
distributors, business contacts, agents, advisers, and government and public bodies – this
includes their advisors, representatives and officials, politicians, and public parties.
c. Any arrangements our company makes with a third party is subject to clear contractual terms,
including specific provisions that require the third party to comply with minimum.


4. Definition of bribery
a. Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or
soliciting something of value or of an advantage so to induce or influence an action or decision.
b. A bribe refers to any inducement, reward, or object/item of value offered to another individual in
order to gain commercial, contractual, regulatory, or personal advantage.
c. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a
bribe and they accept it, they are also breaking the law.
d. Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly,
passively (as described above), or through a third party (such as an agent or distributor). They
must not bribe a foreign public official anywhere in the world. They must not accept bribes in
any degree and if they are uncertain about whether something is a bribe or a gift or act of
hospitality, they must seek further advice from the company’s compliance manager.


5. What is and what is NOT acceptable
a. This section of the policy refers to 4 areas:
i. Gifts and hospitality.
ii. Facilitation payments.
iii. Political contributions.
iv. Charitable contributions.
b. Gifts and hospitality Brave Bear Marketing accept normal and appropriate gestures of
hospitality and goodwill (whether given to/received from third parties) so long as the giving or
receiving of gifts meets the following requirements:
i. It is not made with the intention of influencing the party to whom it is being given, to
obtain or reward the retention of a business or a business advantage, or as an explicit
or implicit exchange for favours or benefits.
ii. It is not made with the suggestion that a return favour is expected.
iii. It is in compliance with local law.
iv. It is given in the name of the company, not in an individual’s name.
v. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
vi. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a
small thank you to a company for helping with a large project upon completion).
vii. It is of an appropriate type and value and given at an appropriate time, taking into
account the reason for the gift.
viii. It is given/received openly, not secretly.
ix. It is not selectively given to a key, influential person, clearly with the intention of
directly influencing them.
x. It is not above a certain excessive value, as pre-determined by the company’s
leadership (not in excess of £100).
xi. It is not offer to, or accepted from, a government official or representative or politician
or political party, without the prior approval of the company’s leadership.
c. Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a
certain religion/culture who may take offence), the gift may be accepted so long as it is
declared to the company leadership, who will assess the circumstances.
d. Brave Bear Marketing recognises that the practice of giving and receiving business gifts varies
between countries, regions, cultures, and religions, so definitions of what is acceptable and not
acceptable will inevitably differ for each.
e. As good practice, gifts given and received should always be disclosed to the company
leadership. Gifts from suppliers should always be disclosed.
f. The intention behind a gift being given/received should always be considered. If there is any
uncertainty, the advice of the company leadership should be sought.
g. Facilitation Payments and Kickbacks Brave Bear Marketing does not accept and will not make
any form of facilitation payments of any nature. We recognise that facilitation payments are a
form of bribery that involves expediting or facilitating the performance of a public official for a
routine governmental action. We recognise that they tend to be made by low level officials with
the intention of securing or speeding up the performance of a certain duty or action.
h. Brave Bear Marketing does not allow kickbacks to be made or accepted. We recognise that
kickbacks are typically made in exchange for a business favour or advantage.
i. Brave Bear Marketing recognises that, despite our strict policy on facilitation payments and
kickbacks, employees may face a situation where avoiding a facilitation payment or kickback
may put their/their family’s personal security at risk. Under these circumstances, the following
steps must be taken:
1. Keep any amount to the minimum.
2. Ask for a receipt, detailing the amount and reason for the payment.
3. Create a record concerning the payment.
4. Report this incident to your line manager.
j. Political Contributions
i. Brave Bear Marketing will not make donations, whether in cash, kind, or by any other
means, to support any political parties or candidates. We recognise this may be
perceived as an attempt to gain an improper business advantage.
k. Charitable Contributions
i. Brave Bear Marketing accepts (and indeed encourages) the act of donating to
charities – whether through services, knowledge, time, or direct financial contributions
(cash or otherwise) – and agrees to disclose all charitable contributions it makes.
ii. Employees must be careful to ensure that charitable contributions are not used to
facilitate and conceal acts of bribery.
iii. We will ensure that all charitable donations made are legal and ethical under local
laws and practices, and that donations are not offered/made without the approval of
the compliance manager.
6. Employee Responsibilities
i. As an employee of Brave Bear Marketing, you must ensure that you read,
understand, and comply with the information contained within this policy, and with any
training or other anti-bribery and corruption information you are given.
ii. All employees and those under our control are equally responsible for the prevention,
detection, and reporting of bribery and other forms of corruption. They are required to
avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.
iii. If you have reason to believe or suspect that an instance of bribery or corruption has
occurred or will occur in the future that breaches this policy, you must notify the
company leadership.
iv. If any employee breaches this policy, they will face disciplinary action and could face
dismissal for gross misconduct. A Managing Director has the right to terminate a
contractual relationship with an employee if they breach this anti-bribery policy.
7. What happens if I need to raise a concern?
a. This section of the policy covers 3 areas:
i. How to raise a concern.
ii. What to do if you are a victim of bribery or corruption.
iii. Protection.
b. How to raise a concern if you suspect that there is an instance of bribery or corrupt activities
occurring in relation to Brave Bear Marketing, you are encouraged to raise your concerns at as
early a stage as possible. If you’re uncertain about whether a certain action or behaviour can
be considered bribery or corruption, you should speak to your line manager.
c. Brave Bear Marketing will familiarise all employees with its whistleblowing procedures so
employees can vocalise their concerns swiftly and confidentially.
d. What to do if you are a victim of bribery or corruption
i. You must tell your manager as soon as possible if you are offered a bribe by anyone,
if you are asked to make one, if you suspect that you may be bribed or asked to make
a bribe in the near future, or if you have reason to believe that you are a victim of
another corrupt activity.
e. Protection if you refuse to accept or offer a bribe or you report a concern relating to potential
act(s) of bribery or corruption, Brave Bear Marketing understands that you may feel worried
about potential repercussions. Brave Bear Marketing will support anyone who raises concerns
in good faith under this policy, even if investigation finds that they were mistaken.
f. Brave Bear Marketing will ensure that no one suffers any detrimental treatment as a result of
refusing to accept or offer a bribe or other corrupt activities or because they reported a concern
relating to potential act(s) of bribery or corruption.
g. Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment
in relation to the concern the individual raised.
h. If you have reason to believe you’ve been subjected to unjust treatment as a result of a
concern or refusal to accept a bribe, you should inform your line manager immediately.
8. Training and communication
a. Brave Bear Marketing will provide training on this policy as part of the induction process for all
new employees. Employees will also receive regular, relevant training on how to adhere to this
policy, and will be asked annually to formally accept that they will comply with this policy.
b. Brave Bear Marketing’s anti-bribery and corruption policy and zero-tolerance attitude will be
clearly communicated to all suppliers, contractors, business partners, and any third-parties at
the outset of business relations, and as appropriate thereafter.
c. Brave Bear Marketing will provide relevant anti-bribery and corruption training to employees
etc. where we feel their knowledge of how to comply with the Bribery Act needs to be
enhanced. As good practice, all businesses should provide their employees with anti-bribery
training where there is a potential risk of facing bribery or corruption during work activities.
9. Record keeping
a. Brave Bear Marketing will keep detailed and accurate financial records, and will have
appropriate internal controls in place to act as evidence for all payments made. We will declare
and keep a written record of the amount and reason for hospitality or gifts accepted and given,
and understand that gifts and acts of hospitality are subject to managerial review.
10. Monitoring and reviewing
a. Brave Bear Marketing leadership is responsible for monitoring the effectiveness of this policy
and will review the implementation of it on a regular basis. They will assess its suitability,
adequacy, and effectiveness.
b. Internal control systems and procedures designed to prevent bribery and corruption are subject
to regular audits to ensure that they are effective in practice.
c. Any need for improvements will be applied as soon as possible. Employees are encouraged to
offer their feedback on this policy if they have any suggestions for how it may be improved.
Feedback of this nature should be addressed to the compliance manager.
d. This policy does not form part of an employee’s contract of employment and Brave Bear
Marketing may amend it at any time so to improve its effectiveness at combatting bribery and
corruption.