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HOW TO RAISE A CONCERN

                   You are encouraged to raise concerns about any issue or suspicion of malpractice
                   at  the  earliest possible stage. If you are unsure     whether a particular act
                   constitutes bribery  or  corruption,  or  if  you  have  any  other  queries,  these  should
                   be raised with your line manager/a Director.


                   PROTECTION

                         Employees who refuse to accept or offer a bribe, or those who raise concerns or
                         report another’s wrongdoing, are sometimes worried about possible
                         repercussions.  The company  aims  to encourage openness and will support
                        anyone who raises genuine concerns in good faith under this policy, even if they
                         turn out to be mistaken.


                            The UK anti-bribery legislation applies to all activities of a UK-based
                             business no matter where they are carried out in the world. This policy
                             therefore  applies to ALL  activities worldwide, whatever the local  law,
                             practice or custom may be.

                             By complying with this policy we aim to ensure that you and the company
                             will not at any  time knowingly breach any relevant anti-bribery and
                          corruption legislation and also that by adhering to the policy the company can
                           demonstrate that it has adequate procedures in place to prevent such activity.

                   All employees have an independent obligation to prevent bribery and corruption in
                   the  company  and  ensure  that  any  interaction  with  public  officials  complies  with
                   this policy and relevant laws.



                   17. OTHER POLICIES



                   The  company  will  require  you  to  comply  with  other  policies  as
                   may    be    introduced   from    time    to   time.   These    policies   will   be
                   circulated and you will be informed at the appropriate time.
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