Owner Driver Anti-bribery & Corruption Policy

Introduction

In this Policy:

Bribe means an incentive or reward, in money or money’s worth in return for doing
something which is illegal, unethical, dishonest, a breach of trust or improper in any way.
Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the
award of a contract or any other advantage or benefit.
Bribery includes offering, promising, giving, accepting or seeking a bribe.

1. Aim of this Policy
1.1 It is our policy to act fairly and ethically wherever we do business. We have promised to
act professionally, fairly and with integrity in all our business dealings and relationships
and we will not tolerate bribery or corruption in our business or those we do business
with.
1.2 If you, your Driver or any other Personnel break the terms of this Policy, we will end your
Franchise Agreement/Worker Contract.
1.3 We may change this Policy at any time and we will review it regularly.

2. What is Bribery?

2. Forms of Bribery
2.1 All forms of bribery are banned.
2.2 If you are not sure if something you are asked to do or not do is, please speak to
Dan Turner (dan.turner@dpdgroup.co.uk), Rob Cheeseman
(rob.cheeseman@dpdgroup.co.uk) and Sund Paul (sund.paul@dpdgroup.co.uk), in
confidence.
2.3 You must not:
(a) give or offer any money, gift, hospitality or other benefit in return for business;
(b) accept an offer to do or not to do something which you know or suspect is made
to give a business advantage to the person making the offer or to someone
else;
2.4 Examples of things you must not do under 2.3(a) include offering money, gifts,
hospitality or other benefits to a DPD employee:-
(a) to give you better treatment than other Owner Driver Franchisees or Workers;
(b) to enter into a Franchise Agreement with you or renew a Franchise Agreement;
(c) to keep secret, breaches of your Franchise Agreement;
(d) not to award you Service Failure Points; or
(e) doing anything else that is not as set out in your Franchise Agreement.

2.5 Examples of things you must not do under 2.3(b) include accepting an offer from another
Owner Driver Franchisee or Worker not to provide Services on a particular route or
routes or to end your Franchise Agreement or Worker Contract.
2.6 Be alert. Don’t ever let yourself be forced into doing something you know or suspect is
wrong. A bribe could be offered by a customer, a supplier, a DPD employee, another
Owner Driver Franchisee or Worker or someone outside of DPD.
2.7 You must not threaten or get your own back on someone who has refused to offer or
accept a bribe or who has reported possible bribery or corruption.

3. Gifts and hospitality
In some parts of DPD, it is accepted that appropriate gifts and hospitality may be given
or accepted for good reasons like building relationships, maintaining our image or
reputation, or marketing our products and services, but there are no circumstances in
which it is reasonable for Owner Driver Franchisees or Workers, their Drivers or
Personnel to give or accept gifts or hospitality.
4. Record-keeping
4.1 You must keep accurate records (including all invoices and receipts) of everything that
you do, especially in relation to the payments you make and what they are for. Proper
records show you have nothing to hide.
4.2 All accounts, invoices, and other records should be accurate and complete. Accounts
must not be kept “off-book” to hide improper payments.

5. How to raise a concern
5.1 If:
(a) you are offered a bribe; or
(b) are asked to make a bribe; or
(c) if you think someone is breaking this Policy or is involved in bribery or corruption
or is about to be (and this includes your Drivers and other Personnel), you must
tell Dan Turner, Rob Cheeseman and Sund Paul as soon as possible.

6. If you, your Driver or any other Personnel break the terms of this Policy, we will
end your Franchise Agreement/Worker Contract.

3. EMPLOYEE/CONTRACTOR ON-BOARDING SCREENING

3.1 Before any individual may supply or render any services to H2O in any context either as an employee, subcontractor, or personnel of a subcontractor a Drug & Alcohol screening test must be performed and a negative sample provided.

4. RANDOM SCREENING

4.1 Whilst contracting to or under the employment of H2O, there shall be a continued requirement for each individual to agree to undertake random drug & alcohol screening tests, for the purpose of verifying compliance with this policy, when requested, by either a representative of H2O or a representative of our client, at whose premises the services are being rendered or supplied.

5. TESTING PROCESS

5.1 All screening tests undertaken by any individual in line with this policy shall be conducted at the expense of H2O, by a suitably qualified and authorised independent Toxicologist, on behalf of the third party appointed by either H2O or a client of H2O to conduct such screening tests.
5.2 Results of all screening tests shall be available to the donor once they are made available to H2O.

6. NON-NEGATIVE RESULT

6.1 Should the result of any screening test undertaken be ‘Non-Negative’, any employee shall be immediately suspended from any duties pending an investigation in line with our disciplinary procedure.
6.2 Should the result of any screening test undertaken be ‘Non-Negative’, any supplier will have any agreement and/or contract for services with H2O Logistics Ltd immediately terminated.

7. RIGHT TO APPEAL

7.1 The donor shall have the right to appeal where in the situation that the onsite testing equipment may be defective; samples will then be sent to an approved Laboratory.
7.2 Further costs/penalties may be incurred subject to result.

Anti Bribery & Corruption

1. ABOUT THIS POLICY

1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
1.2 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any Service Provider or supplier who breaches this policy may have their contract terminated with immediate effect.
1.3 This policy does not form part of any employee’s or worker’s contract of employment or engagement and we may amend it at any time.

2. WHO MUST COMPLY WITH THIS POLICY?

2.1 This policy applies to all persons working for, or providing services to us, or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

3. WHAT IS BRIBERY?

3.1 ‘Bribe’ means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
3.2 ‘Bribery’ includes offering, promising, giving, accepting, or seeking a bribe.
3.3 All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.
3.4 Specifically, you must not:
a)   give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
b)   accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
c)   give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
3.5 You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4. GIFTS AND HOSPITALITY

4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.
4.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers, and business partners.

5. RECORD-KEEPING

5.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
5.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

6. HOW TO RAISE A CONCERN

6.1 If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify a representative of the Management Team either in person or by email to compliance@h2ologistics.co.uk.