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Anti-Bribery Policy

 

1. Introduction

Cooper Software Ltd (trading as ProScope for NetSuite) (hereinafter "the Company") is committed to conducting business with integrity and in compliance with all applicable laws, including the UK Bribery Act 2010. We have a zero-tolerance approach to bribery and corruption and are committed to preventing such activities in all aspects of our operations.

2. Scope

This policy applies to all employees, directors, officers, contractors, consultants, suppliers, and business partners associated with the Company.

3. Definition of Bribery

Bribery is the offering, giving, receiving, or soliciting of anything of value to improperly influence an action or decision. It can take many forms, including:

  • Cash payments or kickbacks

  • Gifts, hospitality, or entertainment intended to secure a business advantage

  • Facilitation payments to expedite routine processes

  • Political or charitable donations intended to influence decision-making

4. Our Commitment

The Company commits to:

  • Prohibiting all forms of bribery and corruption in our business dealings.

  • Ensuring all employees and associated persons act honestly and with integrity.

  • Conducting due diligence on third parties to assess bribery risks.

  • Encouraging the reporting of any suspected bribery incidents.

5. Responsibilities

  • Senior Management: Responsible for overseeing and enforcing this policy.

  • Employees & Contractors: Required to comply with this policy and report any concerns.

  • Suppliers & Business Partners: Expected to uphold similar anti-bribery standards and practices.

6. Gifts, Hospitality, and Donations

  • Gifts and hospitality must be reasonable, proportionate, and not intended to secure an improper advantage.

  • Charitable and political donations must be transparent and not linked to any business decision.

  • Employees must seek approval before offering or accepting significant gifts or hospitality.

7. Reporting and Whistleblowing

Any suspected bribery must be reported to the CFO via webform. Reports will be treated confidentially, and whistleblowers will be protected from retaliation.

8. Training and Awareness

We provide regular training to employees on anti-bribery laws and best practices to ensure compliance.

9. Policy Review

This policy will be reviewed annually and updated as necessary to ensure ongoing compliance with relevant laws and best practices.

Approved by: Marc Cooper
Date: 05/11/2024