Anti-bribery & anti-corruption policy

Drinks21 Ltd conducts business honestly. We prohibit bribery and corruption in every form, in every market in which we operate, without exception and regardless of local custom or commercial consequence.

We are committed to compliance with the Bribery Act 2010 and with all applicable anti-bribery and anti-corruption laws in the jurisdictions where we trade, including the US Foreign Corrupt Practices Act where it applies to our dealings.

We trade into markets where corruption risk is, on any objective measure, higher than in the United Kingdom. That is precisely why this policy exists and why it is not negotiable.

What is prohibited

No director, employee, agent or representative of Drinks21 may offer, promise, give, request, agree to receive or accept a financial or other advantage intended to induce or reward the improper performance of a function or activity, whether directly or through a third party, and whether the counterparty is a private business or a public official. This includes:

• Bribes in any form: cash, goods, services, favours, employment offers, or anything else of value.
• Facilitation payments, meaning small unofficial payments to secure or speed up a routine action to which we are already entitled. These are illegal under UK law and we do not make them, even where they are locally customary and even where refusing causes delay or cost.
• Kickbacks, meaning returning any portion of a contract payment to an individual connected with awarding it.
• Bribery through third parties, meaning using an agent, distributor, consultant or intermediary to do what we could not do directly. Under section 7 of the Bribery Act, we can be liable for bribery committed by an associated person on our behalf.
• Political donations made to obtain business advantage. Drinks21 does not make political donations.

Gifts and hospitality

Reasonable and proportionate corporate hospitality is a normal and legitimate part of the drinks trade. Product samples, trade tastings, hosted dinners and attendance at industry events are ordinary business practice, and this policy is not intended to prohibit them.

Gifts and hospitality are acceptable where they:

• Are made openly, not secretly
• Are reasonable and proportionate in value and frequency to the relationship
• Are given in the name of Drinks21, not an individual
• Do not include cash or a cash equivalent
• Are not given with the intention of influencing a decision or obtaining an improper advantage
• Comply with local law in the recipient's jurisdiction
• Would not embarrass us if they were made public

Particular caution applies to public officials, customs officers and regulatory staff. Hospitality for anyone in that category requires prior approval from a director. If you are unsure whether something is appropriate, it probably isn't. Ask first.

Our expectations of trading partners

Our terms and conditions of sale require every trade customer to comply with applicable anti-bribery and anti-corruption laws, including the Bribery Act 2010, to refrain from any activity constituting a bribe or facilitation payment, to maintain adequate procedures to prevent bribery, and to provide evidence of those procedures on request.

We expect the same of suppliers, agents and intermediaries. Where we appoint a third party to act on our behalf in a market, we conduct proportionate due diligence on that party before appointment and require a contractual commitment to this policy.

Record keeping

All payments, receipts, expenses, gifts and hospitality are recorded accurately in our financial records. We do not maintain off-book accounts. We do not accept cash for goods in any amount, and payment must be made from an account in the customer's own name. Records are retained for a minimum of five years and are available for inspection by HMRC or other competent authorities.

Raising a concern

If you believe a bribe has been requested, offered or paid in connection with Drinks21, report it immediately to a director at sales@drinks21.com or +44 (0) 1344 294 170.

We will support anyone who raises a genuine concern in good faith, even if it turns out to be mistaken. Nobody will suffer detrimental treatment for refusing to participate in bribery or for reporting a concern. Refusing a bribe may cost us business. We accept that cost.

Concerns can also be raised with the UK's Serious Fraud Office, or anonymously via the independent whistleblowing charity Protect on 020 3117 2520.

Consequences of breach

Breach of this policy by an employee is a disciplinary matter and may constitute gross misconduct. Breach by a customer, supplier or agent entitles us to terminate the relationship immediately. Individuals convicted under the Bribery Act face up to ten years' imprisonment and an unlimited fine; companies face an unlimited fine and disqualification from public contracts.

Review

This policy is reviewed annually and following any material change in legislation or our operations. Responsibility for it sits with the directors of Drinks21 Ltd. Questions: sales@drinks21.com.