Anti-Bribery and Corruption Policy

1. Introduction

NEIC Ltd is committed to conducting its business with the highest standards of integrity and in full compliance with all applicable laws and regulations. This Anti-Bribery and Corruption Policy outlines our zero-tolerance approach towards bribery and corruption and provides guidance for our employees, contractors, and suppliers to ensure that all business activities are conducted ethically and in accordance with the Bribery Act 2010.

2. Policy Statement

NEIC Ltd prohibits any form of bribery or corruption, whether direct or indirect, in both the public and private sectors. This includes offering, giving, receiving, or soliciting bribes, as well as any form of improper payment or inducement. Our business practices must reflect our commitment to ethical behaviour and fair competition.

3. Scope

This policy applies to all employees, contractors, agents, suppliers, and anyone else acting on behalf of NEIC Ltd, both within the UK and internationally. It is essential that all individuals and entities associated with NEIC Ltd understand and comply with this policy.

4. What is Bribery?

Bribery is the offering, promising, giving, accepting, or requesting something of value with the intention of influencing the actions of an individual or entity in a way that is improper or illegal. This includes:

• Offering or receiving gifts, hospitality, or any other benefit with the intent to influence decisions.
• Offering or receiving payments to secure an advantage in business or government decisions.
• Facilitation payments intended to expedite routine services or approvals.

5. Prohibited Conduct

• Offering, giving, or receiving bribes, including facilitation payments or kickbacks.
• Engaging in corrupt practices, such as influencing decisions to gain unfair business advantages.
• Making donations or gifts with the intention of influencing business decisions.

6. Responsibilities

• Familiarize themselves with and comply with this Anti-Bribery and Corruption Policy.
• Avoid any activity that might lead to, or suggest, a conflict of interest.
• Report any concerns related to bribery or corruption through the appropriate channels, as outlined in our Whistleblowing Policy.

7. Gifts and Hospitality

NEIC Ltd recognizes that the giving and receiving of gifts or hospitality can form part of normal business practices. However, gifts and hospitality must not be used as a means of influencing or rewarding decisions in a way that could be deemed improper. Any gifts or hospitality offered or received must:

• Be reasonable, proportionate, and in line with NEIC Ltd’s guidelines.
• Not be offered or accepted with the intent to influence business decisions.

8. Reporting and Whistleblowing

NEIC Ltd encourages employees and stakeholders to report any concerns regarding bribery or corruption. We provide a safe and confidential whistleblowing system to ensure that concerns are dealt with promptly and appropriately. There will be no retaliation for anyone who reports a concern in good faith.

9. Due Diligence and Third-Party Relationships

We will conduct due diligence on all third parties, including suppliers, agents, and business partners, to assess their compliance with anti-bribery and anti-corruption standards. We expect all third parties to adhere to similar ethical standards and comply with the Bribery Act 2010.

10. Training and Awareness

NEIC Ltd will provide regular training on anti-bribery and corruption policies to ensure that employees understand the risks associated with bribery and how to avoid it. Training will be provided to all employees, with additional training for senior managers and those in procurement or decision-making roles.

11. Monitoring and Enforcement

We will regularly monitor compliance with this policy and take appropriate action in response to any violations. Any employee or third party found to be involved in bribery or corruption will face disciplinary action, up to and including termination of employment or contract.

12. Policy Review

This policy will be reviewed regularly to ensure it remains effective and aligned with the Bribery Act 2010 and other relevant legislation. It will be updated as necessary to reflect any changes in legal or business requirements.

13. Approval

This Anti-Bribery and Corruption Policy has been approved by the Board of Directors of NEIC Ltd. It is our policy to ensure the highest standards of compliance with anti-bribery and corruption laws.

Signed: R. Foster

Rober Foster

Chief Executive Officer, NEIC Ltd