Anti-Bribery Policy

Introduction

CTRM Cubed Limited is committed to responsible corporate governance, and compliance with all laws, regulations and other requirements within our operations.

This statement has been published in accordance with the Bribery Act 2010. It sets out the steps taken CTRM Cubed Limited for the financial year 2021/22 and ensures that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.

Bribery

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.

A bribe refers to any inducement, reward, object or item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

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.

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.

Corruption

Corruption is the misuse of power for private gain. The Bribery Act 2010 makes bribery and corruption a criminal offence and holds companies liable for failing to prevent acts of bribery or corruption by those working for or on its behalf, no matter where the act takes place.

Gifts and hospitality

The company does not allow the giving and receiving of gifts, hospitality or any other benefits above a threshold of £15.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All staff and contractors are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Compliance

Staff are required to notify the company as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee workers if they breach this policy.

If any third party is aware of any activity by any worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with the company’s compliance manager.

Board approval

This statement has been approved by CTRM Cubed’s Board of Directors for the financial year 2021/22.

CTRM Cubed Limited registered in England and Wales (number 10728615) Registered address: Lake View House, Wilton Drive, Tournament Fields, Warwick, CV34 6RG.