Anti-Bribery and Corruption Policy

Fast UK Parcel Ltd

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1. What Does Our Policy Cover?

1. This anti-bribery and anti-corruption policy sets out the responsibility of anyone working for Fast UK Parcel (in any capacity) to observe and uphold our zero-tolerance position on bribery and corruption.

2. This policy also acts as a source of information and guidance for employees, consultants, contractors, and sub-contractors of Fast UK Parcel, to help them identify and address any issues relating to bribery and corruption.

2. Policy Statement

1. Fast UK Parcel is committed to conducting business in an honest, transparent, and ethical manner, adopting zero tolerance to bribery and corruption and ensuring that appropriate systems are in place to recognise and prevent bribery and corrupt activities. We are fully committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the world we operate.

2. In compliance with UK laws relating to anti-bribery and corruption — principally the Bribery Act 2010 — Fast UK Parcel understands that any breach of the Act is punishable with unlimited fines and up to 10 years' imprisonment, and commits to upholding our legal responsibilities in accordance with the terms of this policy.

3. Fast UK Parcel will consistently uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

3. Who is Covered by This Policy?

1. This policy applies to all Fast UK Parcel employees, consultants, sub-contractors, and any other person associated with the company (including third parties), as well as to officers, trustees, subsidiaries and their employees, and board and/or committee members at any level, whether located within or outside the UK.

2. For the purposes of this policy, a "third party" refers to any individual or organisation our company works with, including existing and potential clients, customers, suppliers, business associates, governments, and public bodies, as well as their advisers, representatives and officials, politicians, and political parties.

3. Any arrangements made by Fast UK Parcel with a third party are subject to clear contractual standards and must include specific provisions requiring the third party to comply with the minimum terms of this policy.

4. Definition of Bribery

1. Bribery is an illegal practice defined by the act of offering, giving, promising, asking, receiving, accepting, agreeing to, or soliciting something of value or an advantage that could induce or influence any action or decision.

2. A bribe is any reward, inducement, compensation, or item of value offered to obtain commercial, contractual, regulatory, or personal gain or advantage.

3. Bribery is not limited to offering a bribe. Accepting a bribe also constitutes a breach of this policy and must not be engaged in, in any form, whether directly, passively, or through a third party.

4. Anyone working for Fast UK Parcel in any capacity must not bribe a public official anywhere in the world, or accept bribes of any kind. If you are uncertain whether something qualifies as a bribe, further advice must be sought from the Compliance Manager.

5. What is Not Acceptable

This section of the policy covers the following four areas:

• Gifts and hospitality

• Facilitation payments and kickbacks

• Political contributions

• Charitable contributions

5.1 Gifts and Hospitality

The general rule is that Fast UK Parcel employees and consultants may only accept gifts of low value and appropriate acts of hospitality, provided that the gift or act of hospitality:

• is not made to influence the recipient to obtain or reward the retention of business or a business advantage, or as an explicit or implicit exchange for favours or benefits;

• is not offered with the suggestion that a return favour is expected;

• is in full compliance with local law;

• is given in the company's name, not in the name of an individual;

• does not include cash or a cash equivalent (e.g. a voucher or gift certificate);

• is appropriate for the circumstances (e.g. small gifts around Christmas, or a small thank-you to a company on completion of a large project);

• is of an appropriate value and type, and given at an appropriate time, considering the reason for the gift;

• is given or received openly, not secretly;

• is not selectively given to a key or influential person in a way clearly intended to influence them directly;

• is not above an excessive value (usually over £100); and

• is not offered to, or accepted by, a government official, representative, politician or political party without the prior approval of the company's Compliance Manager.

• Where it would be inappropriate to decline the offer of a gift or act of hospitality (e.g. when meeting an individual of a certain religion or culture who may take offence), the gift may be accepted, provided it is declared to the Compliance Manager, who will assess the circumstances.

• Fast UK Parcel recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions; definitions of what is and is not acceptable will therefore inevitably differ.

• The intention behind any gift or act of hospitality should always be considered; in cases of uncertainty, the advice of the Compliance Manager should be sought.

• As good practice, gifts given and received should always be disclosed to the Compliance Manager. Gifts from suppliers must always be disclosed.

5.2 Facilitation Payments and Kickbacks

• Fast UK Parcel recognises that facilitation payments are a form of bribery — payments made to facilitate or speed up a routine governmental action, typically by low-level officials. We will not accept or make facilitation payments of any nature.

• Fast UK Parcel understands that kickbacks are typically made in exchange for a business favour or advantage; we will not allow kickbacks to be made or accepted.

• Fast UK Parcel recognises that, despite our strict policy, the workforce may face a situation where refusing or avoiding a facilitation payment or kickback could put their own or their family's personal security at risk. In such circumstances, the following steps must be taken:

  • keep any amount paid to the minimum;

  • ask for a receipt detailing the amount and reason for payment;

  • create a record concerning the payment; and

  • report the incident to the line manager.

5.3 Political Contributions

• Fast UK Parcel will not make donations or contributions, monetary or otherwise, to support any political parties or candidates, as we recognise this may be perceived as an attempt to gain a business advantage.

5.4 Charitable Contributions

• Fast UK Parcel accepts and encourages donations — whether through services, knowledge, time, or direct financial contributions (cash or otherwise) — to charities that are legal and ethical, and agrees to disclose all charitable contributions made.

• The workforce must take care to ensure that charitable contributions are not used to facilitate or conceal acts of bribery.

• Fast UK Parcel will ensure that all charitable donations are legal and ethical under local laws and practices, and that no donation is offered or made without the approval of the Compliance Manager.

6. Workforce Responsibilities

1. All employees, consultants, and sub-contractors must ensure that they read, understand, and comply with the information contained within this policy and any anti-bribery and corruption training or information provided.

2. All employees, consultants and sub-contractors are responsible for the prevention, detection, and reporting of bribery and any other form of corruption, and are required to refrain from any activity that could lead to, or imply, a breach of this policy.

3. Anyone with reason to believe or suspect that an instance of bribery or corruption has occurred, or may occur in the future, must notify the Compliance Manager.

4. A breach of this policy by an employee will be subject to disciplinary action and could result in dismissal for gross misconduct. If a sub-contractor breaches this policy, Fast UK Parcel will no longer maintain its offer of services. Any breach of this policy can lead to termination.

7. Raising Concerns

This section of the policy covers three areas: how to raise a concern; what to do if you are a victim of bribery or corruption; and protection.

How to Raise a Concern

• If you suspect that an instance of bribery or corrupt activity is occurring in connection with Fast UK Parcel, you are encouraged to raise your concern as soon as possible. If you are uncertain whether a particular action or behaviour constitutes bribery or corruption, advice must be sought from the line manager, Compliance Manager, director, or the Head of Governance and Legal.

• Fast UK Parcel will familiarise all of the workforce with its whistleblowing procedures so that any concerns can be raised swiftly and confidentially.

What to Do if You Are a Victim of Bribery or Corruption

• Anyone who has been offered a bribe, asked to make one, suspects they may be offered or asked for a bribe in the near future, or has reason to believe they are a victim of another corrupt activity, must report their concerns to the Compliance Manager as soon as possible.

Protection

• Fast UK Parcel understands that, when refusing to accept or offer a bribe or when reporting concerns relating to bribery and corruption, the workforce may feel worried about potential repercussions. Fast UK Parcel will therefore support anyone who raises concerns in good faith under this policy, even if the outcome of the investigation finds that they were mistaken.

• Fast UK Parcel will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe, or of voicing their concerns about a potential act of bribery or corruption.

• If anyone who has reported an instance of bribery or corruption, or voiced their concerns, believes they have been subjected to unjust treatment as a result of complying with the terms of this policy, this must be reported to the line manager or Compliance Manager immediately.

8. Training and Communication

1. Fast UK Parcel will provide training on this policy as part of the induction process for everyone engaging with the company (as appropriate). The workforce will also receive regular, relevant training on how to adhere to this policy and will be asked to formally confirm that they will comply with it.

2. Fast UK Parcel's anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, sub-contractors, business partners, and any third parties at the outset of business relations and as appropriate thereafter.

3. Fast UK Parcel will provide relevant anti-bribery and corruption training to employees, contractors, sub-contractors and others, to enhance their knowledge of how to comply with the Bribery Act 2010. As good practice, all businesses should provide their workforce with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities.

9. Record Keeping

1. Fast UK Parcel will keep detailed and accurate financial records and ensure the appropriate internal controls are in place to act as evidence for all payments made. Any gifts or acts of hospitality given or received must be declared and logged accordingly, including the amount and reason, and are subject to managerial review.

10. Monitoring and Reviewing

1. Fast UK Parcel's Compliance Manager is responsible for monitoring and maintaining the effectiveness of this policy, and will review its suitability, adequacy, and effectiveness regularly, implementing any changes whenever necessary.

2. Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure their effectiveness in practice.

3. Any need for improvement will be addressed as soon as possible. Employees, consultants, and sub-contractors are encouraged to offer feedback on this policy and any suggestions for how it can be improved. Feedback and suggestions should be addressed to the Compliance Manager.

4. This policy does not form part of the contract of employment, and the company may amend it at any time to improve its effectiveness in combating bribery and corruption.