Anti-Bribery and Corruption Policy

Version: 1.4

Effective Date: 15 July 2022

Review Date: 15 July 2023

Registered Address: 71–75 Shelton Street, Covent Garden, London WC2H 9JQ

1. Purpose and Commitment

Equity Sherpa is committed to conducting all of its business with the highest standards of honesty, integrity, and professionalism. The company has a zero tolerance approach to bribery and corruption and will uphold all applicable anti-bribery and corruption laws, including the UK Bribery Act 2010.

The directors of Equity Sherpa take full responsibility for promoting ethical business practices and expect the same from all employees, associates, contractors, and business partners. The company’s objective is to ensure that all business dealings are carried out transparently, fairly, and in compliance with the law.

2. Scope

This policy applies to all directors and employees of Equity Sherpa (this will be a three-person consultancy that might also use associates).

3. Definitions

  • Bribery: Offering, promising, giving, requesting, or accepting anything of value to improperly influence the actions of another person.
  • Corruption: Abuse of entrusted power for private gain.

4. Responsibilities

Employee and Associate Responsibilities

All employees and associates must:

  • Refrain from offering, giving, requesting, or accepting bribes in any form.
  • Avoid engaging in conduct that could be perceived as corrupt or improper.
  • Conduct all business dealings in a transparent, fair, and lawful manner.
  •  Exercise caution when giving or receiving gifts or hospitality, ensuring these are modest,
    proportionate, and not intended to influence a business decision.
  • Report any suspicions of bribery or corruption without delay.

Failure to comply with this policy may result in disciplinary action and could lead to criminal prosecution.

Management Responsibilities

The directors of Equity Sherpa are responsible for:

  • Setting the tone of integrity and leading by example.
  •  Ensuring all employees, associates, and contractors are aware of this policy and their obligations under the UK Bribery Act 2010.
  • Responding promptly and appropriately to any concerns raised.
  •  Investigating all reports thoroughly and taking corrective action where necessary.
  • Reviewing the policy periodically to maintain its effectiveness and compliance with the
    law.

5. Reporting Procedures

Any employee, associate, or contractor who suspects bribery or corruption must:

  1. Report the concern directly to a director, either verbally or in writing.
  2. Provide sufficient detail to enable an appropriate investigation.
  3.  Be assured that reports will be treated confidentially, and that there will be no retaliation
    against anyone raising concerns in good faith.

The directors will investigate all reports and, where appropriate, notify relevant authorities.

6. Review and Oversight

This policy will be reviewed annually, or sooner if changes in legislation or business practices
require it. The directors of Equity Sherpa are responsible for ensuring the policy remains fit for purpose.

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