Anti Bribery Policy

W. M. IRONWORK LTD, NEWTON TRACEY, BARNSTAPLE, DEVON, EX31 3PN
Tel: 01271 858444
www.wmi.uk.com

Quality Policy

Extension to Bribery Policy summary contained in the W. M. Ironwork Ltd – Company Handbook
Created and issued January 2020
To be reviewed and revised (if required) annually
Reviewed: 10/09/2025

Introduction

The Company is committed to implementing and enforcing effective systems to counter bribery.
Therefore, it is the Company’s policy to conduct all aspects of its business in an honest and ethical manner at all times.

Under UK law (UK Bribery Act 2010), bribery and corruption is punishable for individuals by up to ten years imprisonment.
If the Company is found to have taken part in the corruption or lacks adequate procedures to prevent bribery,
it could face an unlimited fine and be excluded from tendering for Government contracts.

Policy

The aim of this policy is to help the Company act in accordance with the Bribery Act 2010, maintain the highest possible
standards of business practice, and advise individuals of the Company’s zero-tolerance approach to bribery.

This policy applies to all permanent and fixed-term staff employed by the Company, and any contractors, consultants,
or other persons acting under or on behalf of the Company.

The Company will not:

• Make contributions of any kind with the purpose of gaining any commercial advantage.
• Provide gifts or hospitality with the intention of persuading anyone to act improperly, or to influence a public official.
• Make or accept “kickbacks” of any kind.

Company Responsibility

• Keep appropriate internal records that evidence the business reason for making any payments to third parties.
• Encourage employees to raise concerns about any issue or suspicion of malpractice at the earliest possible stage.
• Ensure anyone raising a concern will not suffer detriment, even if they are mistaken.

Employee Responsibility

Employees must not:

• Accept any financial or other reward from any person in return for providing a favour.
• Request a financial or other reward for providing a favour.
• Offer any financial or other reward in return for providing a favour.

Fraud & Malpractice

Any suspected instances of fraud or malpractice by individuals working for the company or outside agencies should be
reported immediately using the Company Confidential Reporting Channel. Reports will be investigated by senior management.

Reporting and Investigation

All suspected breaches must be reported through the Confidential Reporting Channel. The Compliance Manager will investigate
alongside senior management and accounts where possible.

Should an investigation uncover a breach, the company will act in accordance with the Non-Compliance section and —
where laws have been breached — notify relevant authorities.

Competition Law

The company will comply with UK and international competition laws. This includes not engaging in:

• Price fixing
• Bid rigging
• Market sharing
• Sharing sensitive information

Any concerns regarding these activities should be reported to the Compliance Manager or via the Confidential Reporting Channel.

Non-Compliance

All employees have a role in enforcing this policy. If employees feel unsafe addressing a breach, they should seek senior
management support.

Failure to comply may lead to job role confusion, underperformance risks, and disciplinary action up to and including dismissal.

Implementation of the Policy

Policy implementation and review rests with senior management. All employees must support the policy.
Existing employees will be informed, and new employees will be notified during induction.

The policy is implemented through procedures for appraisals, one-to-one meetings, templates, and guidance for managers and staff.

Communication of the Policy

All new hires will receive this policy during induction. Significant revisions will be communicated to all staff as required.

Monitoring Policy

The policy will be monitored on an ongoing basis to assess effectiveness.

Reviewing Policy

The policy will be reviewed and revised when legislation, codes of practice, or organisational changes require it.

Policy Amendments

If amendments or updates occur, senior management will ensure all relevant employees are notified.
Written notice and/or training will be provided where appropriate.

Additional Information

For more information, contact your manager. If dissatisfied with a decision, use the Company’s formal Grievance Procedure.

Statutory provisions reflected in this policy will update automatically if legislation changes.