Anti-Slavery and Anti-Bribery Policies

Anti-Bribery Policy

Definitions

Bribery Laws”: means laws relating to countering bribery and corruption in all the jurisdictions in which You and/or We operate and includes (without limitation) the Bribery Act 2010 (as amended) and all statutory instruments related to the same.

Us”, “We”, “Our”: means Itec Systems Limited.

Overview

It is Our policy to conduct all of Our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all Our business dealings and relationships wherever We operates and implementing and enforcing effective systems to counter bribery and corruption.

This policy may be updated by Us from time to time at Our absolute discretion.

Compliance with relevant requirements

Itec Systems Ltd and any of its personnel shall:

  • comply with all applicable laws, statutes, regulations, and codes relating to anti-bribery and anti-corruption (“Relevant Requirements”), including [but not limited to Bribery Laws;
  • not engage in any activity, practice or conduct which would constitute an offence under sections 1, 2 or 6 of the Bribery Act 2010 if such activity, practice or conduct had been carried out in the UK;
  • not do, or omit to do, any act that will cause any of our clients to be in breach of any of the Relevant Requirements;
  • promptly report any request or demand for any undue financial or other advantage of any kind received;
  • have and shall maintain in place its own policies and procedures, including but not limited to adequate procedures under the Bribery Act 2010, to ensure compliance with the Relevant Requirements, and will enforce them where appropriate;
  • if requested, provide any reasonable assistance, at reasonable cost, to enable any of our clients to perform any activity required by any relevant government or agency in any relevant jurisdiction for the purpose of compliance with any of the Relevant Requirements.

Additional audit and record keeping

Without prejudice to any other recordkeeping requirement in any agreement, We shall keep all records necessary to evidence compliance with this policy and Bribery Laws and allow authorised agents access to Our premises and records to confirm such compliance.

In the event that of any reasonable grounds to suspects that We or any person associated with Us is in breach of this policy, We shall allow any authorised agents to immediately access and take copies of any records and any other information held at Our premises and to meet with Our personnel to audit Our compliance with Our obligations under this policy. We shall give all necessary assistance to the conduct of such audit during the term of the Agreement and for a period of three years after termination of the Agreement.

We shall keep at Our normal place of business detailed, accurate and up to date records and books of account showing all payments made by Us in connection with any agreement and the steps taken by Us to comply with the Relevant Requirements during the previous three years. We shall ensure that such records and books of accounts are sufficient to enable authorised agents to verify Our compliance with Our obligations under this policy.

Anti-Bribery Charges

We confirm that:

  • neither We nor any of Our officers, employees or other persons associated with it Us:
    • have/has been convicted of any offence involving bribery or corruption, fraud or dishonesty;
    • having made reasonable enquiries, so far as it is aware have/has been or is the subject of any investigation, inquiry or enforcement proceedings by any governmental, administrative or regulatory body regarding any offence or alleged offence under Bribery Laws; or
    • has been or is listed by any government agency as being debarred, suspended, proposed for suspension or debarment, or otherwise ineligible for participation in government procurement programmes or other government contracts including ,without limitation, any exclusion under regulation 57 of the Public Contracts Regulations 2015 (SI 2015/102) or regulation 80 of the Utilities Contracts Regulations 2016 (SI 2016/274);
  • none of Our officers or employees or any person associated with Us or any other person who is performing services in connection Us is a foreign public official; and
  • no foreign public official owns a direct or indirect interest in Us or any person associated with it and no public official has any legal or beneficial interest in any payments made to us.

If at any time Our circumstances, knowledge or awareness change so that We cannot continue to give the assurances set out in the paragraph above, then We shall promptly notify our customers.

Subcontractors

Where the use of a subcontractor is permitted by any Agreement, in addition to the other matters to be included in the terms with any such subcontractor required by an Agreement, the terms shall include written assurances that:

  • impose on and secure from the subcontractor obligations, liabilities, undertakings, warranties, acknowledgements and grants of rights equivalent to those imposed on and secured from Us in this policy (“Relevant Terms and Conditions”); and
  • include provisions, directly enforceable by Us under the Contracts (Rights of Third Parties) Act 1999, granting authorised agents to allow them to audit the records, information and personnel of the subcontractor and their compliance with the Relevant Terms and Conditions.

If the subcontractor fails to perform or observe any of the Relevant Terms and Conditions, We shall inform authorised agents and governing bodies of this and if the breach is material and not capable of remedy, then the subcontract should be terminated by Us.

Anti-Slavery Policy

Definitions

Anti-Slavery Laws”: means laws relating to countering slavery, servitude and human trafficking in all the jurisdictions in which You and/or We operate and includes (without limitation) the Modern Slavery Act 2015 (as amended) and all statutory instruments related to the same.

Us”, “We”, “Our”: means Itec Systems Ltd

Overview

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all Our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in Our own business or in any of Our supply chains.

We are also committed to ensuring there is transparency in Our own business and in Our approach to tackling modern slavery throughout Our supply chains.  We expect the same high standards from all of all of Our contractors, suppliers and other business partners and those who supply services to our clients; We have therefore prepared this policy.

This policy may be updated by Us from time to time at Our absolute discretion.

Compliance with Anti-Slavery and Human Trafficking Laws

In providing Our services to Our clients, We shall:

  • comply with all Anti-Slavery Laws;
  • have and maintain throughout the Agreement Your own policies and procedures to counter slavery, servitude and human trafficking;
  • not engage in any activity, practice or conduct that would constitute an offence under sections 1, 2 or 4, of the Modern Slavery Act 2015 if such activity, practice or conduct were carried out in the UK; and
  • include in Our contracts with Our subcontractors and suppliers anti-slavery and human trafficking provisions that are consistent with the requirements of this policy and procure that each of Our subcontractors and suppliers has obligations in its contracts with its subcontractors and suppliers that prohibit the engagement in any activity, practice or conduct that would constitute an offence under Anti-Slavery Laws.

Due Diligence

From time to time, We shall conduct due diligence exercises in connection with Anti-Slavery Laws which may include issuing questionnaires to Our suppliers who shall respond to the same without delay and provide complete and accurate responses to any questions raised and shall provide Us with any required documentation in connection with such questionnaire.

At the date of the Agreement, We confirm that neither Us nor any of Our officers, employees or other persons associated with Us:

  • have/has been convicted of any offence involving slavery and human trafficking; and
  • having made reasonable enquiries, so far as We are aware, has been or is the subject of any investigation, inquiry or enforcement proceedings by any governmental, administrative or regulatory body regarding any offence or alleged offence of or in connection with slavery and human trafficking.

If We become aware of any reason why the above statement cannot be repeated at any time during the term of the Agreement, then We shall inform Our clients immediately.

We agree that:

  • We have (and implement) due diligence procedures for Our subcontractors and suppliers and other participants in Our supply chains, to ensure that there is no slavery or human trafficking in its supply chains; and
  • We have not identified any part of Our business that We consider to carry a risk of slavery, servitude and/or human trafficking.

Materials and Products

We undertake not to purchase any materials and/or products that have been produced/sourced using forced labour.

Reporting

In the event that We become aware of:

  • any breach, or potential breach, of this Policy; or
  • any breach of the Anti-Bribery Laws; or
  • any actual or suspected slavery or human trafficking in a supply chain which has a connection with the Agreement,

We shall inform Our clients.

 Records

We shall:

  • permit authorised agents, on reasonable notice during normal business hours to have access to and take copies of Our records and any other information and to meet with Our personnel to audit Our compliance with this policy; and
  • maintain a complete set of records to trace the supply chain of all the services We provide in connection with the Agreement; and
  • undertake annual audits of Our supply chain to monitor compliance with Anti-Slavery Laws.

Training

We shall ensure that We carry out regular training for all Our employees, officers and other representatives to ensure compliance with this policy and Our own polices concerned with combatting slavery and human trafficking.