Anti-Bribery Policy

The Bribery Act, recently enacted in the UK, introduces a new consolidated scheme of bribery offences, the key provisions of which are:

• Two general offences covering the offering, promising or giving of a bribe and the requesting of, agreeing to receive or accepting a bribe.


• A distinct offence of bribing a foreign public official to obtain or retain business.


• A new strict liability offence for commercial organisations where they fail to prevent bribery by those acting on their behalf, wherever in the world they may be.

The Bribery Act exposes Revera Limited and its employees to liability that could result in:

• Individuals in the UK being jailed for up to 10 years and/or receiving an unlimited fine.


• Revera Limited receiving an unlimited fine.

Revera Limited values its reputation for professionalism and trust. We recognise that over and above any financial damage suffered, fraud may reflect adversely on our image and reputation.

Revera Limited is therefore committed to preventing bribery and to promoting a culture where bribery is unacceptable.

The purpose of the following Policy Statement is to set out Revera Limited’s aims with regard to limiting its exposure to bribery by:

• Setting out a clear anti-bribery policy to prevent corruption and bribery.


• Providing awareness training to employees so that they can recognise and avoid the use of bribery by themselves and others.


• Encouraging employees to be vigilant and to report any suspicions of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately.


• Monitoring and rigorously investigating instances of alleged bribery and assisting police and other appropriate authorities in any resultant prosecution.


• Taking firm and vigorous action against any individual(s) involved in bribery.

Scope

The following Policy Statement applies equally to all Directors and staff retained by the business, consultants acting on behalf of Revera Limited, and any organisations, or other third parties, with which and through whom Revera Limited conducts business.

Policy Statement

Revera Limited prohibits the offering, the giving, the solicitation or the acceptance of any bribe in order to gain any commercial, contractual or regulatory advantage for Revera Limited in a way which is unethical, or in order to gain any personal advantage for the individual or anyone connected with the individual.

If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to Renshaw Watts, Director of Revera Limited.

Responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees of Revera Limited

There may be situations faced by individuals in which the correct course of action is not always obvious or clear. It is an individual’s responsibility to supplement this policy with their own common sense, following the spirit of the policy as well as its content. Otherwise faced with uncertainty, an individual should ask themselves:

• Do I have any doubts about the legality or the ethics of what I am doing or being asked to do?


• Would I have any concerns about what I am doing being public knowledge?


• Would I have any trouble explaining what I am doing to family or friends?

If anyone is asked to do something that they suspect is illegal, unethical or against Revera Limited’s Anti-Bribery policy or any other codes of conduct, then they must make the matter known to Renshaw Watts, Director of Revera Limited.

Policy Implementation

This policy will be communicated to all employees and be available to all.