2 Hopkins Architects TN B111 Anti-Bribery and Corruption Policy

Rev A Oct 2011

TN B111 Anti-Bribery and Corruption Policy

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Introduction It is the Practices policy to conduct business in an honest way and without the use of corrupt practices or acts of bribery to obtain an unfair advantage. We are committed to ensuring adherence to the highest level and ethical standards. This is not just a cultural commitment on the part of the Practice; it is a moral issue and a legal requirement. In the UK the Bribery Act 2010 not only makes bribery and corruption illegal, but also holds UK companies liable for failing to implement adequate procedures to prevent such acts by those working for the Practice or on its behalf, no matter where in the world the act takes place. Hopkins Architects does not engage in bribery or any form of unethical inducement or payment including facilitation payments and kickbacks. All partners, employees and contract staff are required to avoid any activities that might lead to, or suggest, a conflict of interest with the business of the Practice. Hopkins Architects encourages employees to consider where a relationship or potential relationship, or situation may give rise to the opportunity for an act of bribery or corruption to occur. Where any instance is of a potential concern, employees must raise their observation to a Senior Partner at the earliest possible stage.

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Definition Bribery and corruption can be defined as follows: Bribery is the offer, promise, giving, demanding or acceptance of anything of value, whether directly or indirectly, to obtain, retain or direct business or to secure any improper business advantage. Corruption is the misuse of public office or power for private gain; or misuse of private power in relation to business outside the realm of government.

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Gifts, Entertainment and Hospitality Gifts, entertainment and hospitality include the receipt or offer of gifts, meals, tokens of appreciation and gratitude, or invitations to events, functions, or other social gatherings, in connection with matters related to the business of the Practice. These are not criminalised under the aforementioned Act provided they are reasonable and proportionate. How to evaluate what is acceptable 1. What is the intent is it to build a relationship or is it something else? 2. What is the value? While this is not the only way to determine that a gesture could be deemed a bribe, or corrupt, it is something we must consider is it reasonable and proportionate in the circumstances? 3. When? Is the gift being given before or after a contract has been awarded? Before may be deemed a bribe, after could be deemed a genuine thank you. 4. How would this look if these details were published on the front page of an industry magazine?

Prepared By: Hannah Dickenson Updated By: NA Checked By: Ellis Whittam

3 Hopkins Architects TN B111 Anti-Bribery and Corruption Policy Rev A Oct 2011

5. What if the situation were to be reversed would there be a double standard? If you find it difficult to answer one of the above questions, there may be a risk involved which could potentially damage the Practices reputation or business and you will need to identify the issue with a Senior Partner. For the avoidance of doubt, if you are offered any type of gift or perk, or indeed you are in a position of offering to another party something of value, we will log this information centrally with the HR department. We will record what is being offered, in relation to which project, potential project or subject, the approximate value, the date, the circumstances behind the gift, and finally who approved it. Possible circumstances that are usually acceptable include: Modest/occasional meals or drinks with someone with whom we do business Occasional attendance at ordinary sports, theatre and other cultural events Gifts of nominal value, such as pens, or small promotional items

The Senior Partners have the primary responsibility for implementing this policy. If any instance of bribery or corruption is identified the Senior Partners will take remedial steps immediately.

Prepared By: Hannah Dickenson Updated By: NA Checked By: Ellis Whittam