This hospitality decision tree can help you decide whether or not to offer corporate hospitality. If in doubt, please contact [insert name]. Notes Note 1—Government officials For government officials, local laws impose even stricter legal hospitality-giving limits—see our Gifts and hospitality—government officials policy, which you can find [insert where staff can find the policy]. Note 2—Decision making It is important that the offer of hospitality should not be capable of raising the inference that it was intended to have a direct impact on the recipient’s decision making. If

This table sets out limits to the value of permissible gifts/hospitality by country. If you need information relating to a country not listed here, please contact [insert name]. All amounts are per person, per event or per item. The following table contains details of acceptable values for gifts and hospitality given or received in countries we commonly do business with: As at [insert date] European Union EUR USA USD Australia AUD China CHY [ [Insert

1 Introduction 1.1 We run our business[es] with integrity. All of us must work together to ensure our business[es] remain[s] untainted by bribery and corruption. 1.2 This FAQ document, which is integral to that effort, guides us on how we can best achieve our business goals in a way that is consistent with our commitment to counter bribery and corruption. 2 What type of anti-bribery due diligence is required when making an acquisition? 2.1 The due diligence to be conducted for acquisition targets is similar to that required for agents and intermediaries. However, due diligence concerning an acquisition target requires more in-depth analysis than due diligence of an agent or intermediary often does. This is because an acquiring party can be held accountable for past breaches and other wrongdoing of a target if it has not adequately investigated the possibility of such behaviour and not included proper representations, warranties and indemnities in relevant contracts. 2.2 Conducting

Question Correct answer 1. How many new offences does the Bribery Act 2010 create? (b) Four 2. What is the ‘bribing another person’ offence? (c) Offering or giving something to someone else in return for them doing something for you improperly 3. Would you be committing an offence if you were to accept a large

How to use this test These questions are designed to test your understanding after your attendance at our training on avoiding bribery and corruption. After you have completed this test, please return it to [insert name]. General Name of person completing test [Insert name] Role [Insert role] Date [Insert date] Multiple choice questions Circle the correct answer. Question Multiple choice answers 1. How many offences does the Bribery Act 2010 contain? (a) Three(b) Four(c) Ten 2. What is the ‘bribing another person’ offence? (a) Trying to bribe an individual with the intention of influencing that individual

The Ministry of Justice (MoJ) guidance on the procedures commercial organisations should put in place to prevent bribery is crafted around six principles. The principles are not prescriptive; they are intended to be flexible and outcome-focused. Bribery prevention procedures should be proportionate to the risk of bribery faced by the organisation. It follows that the procedures put in place to implement an organisation’s bribery prevention policies should be designed to: • mitigate identified risks, and • prevent deliberate unethical conduct on the part of associated persons An important aspect of those procedures is the communication of your policies and procedures to staff (of all levels), and training in their application. This is reinforced by MoJ principle 5—Communication (including training). This Practice Note discusses some of the ways you can train staff and raise awareness about anti-bribery and corruption issues. Top-level commitment One of the key messages running through MoJ guidance on anti-bribery and corruption procedures is top-level commitment. Effective leadership in bribery prevention will take a variety of forms appropriate for

1 Bribery Laws means the Bribery Act 2010 [and associated guidance published by the Secretary of State for Justice under the Bribery Act 2010] [and all other applicable UK legislation, statutory instruments and regulations in relation to bribery or corruption] [and any similar or equivalent legislation in any other relevant jurisdiction [including [specify]] ]. 2 Each Party shall comply with applicable Bribery Laws [and all Internal Bribery Policies relating to prevention of bribery and corruption], and each shall [use all reasonable endeavours to] ensure that: 2.1 all of that Party’s personnel; 2.2 all

1 Bribery Laws means the Bribery Act 2010 [and all other applicable UK legislation, regulations and codes in relation to bribery or corruption] [and any similar or equivalent

Commencement Date means the date on which this Agreement is signed by both Parties; Default means any breach of the obligations of the relevant party (including[ but, not limited to, ]abandonment of this Agreement in breach of its terms, repudiatory breach or breach of a fundamental term) or any other default, act, omission, negligence or statement: (a) in the case of the Authority, of its employees, servants, agents; or (b) in the case of the Supplier, of its Sub-contractors or any Supplier's Personnel, in connection with or in relation to this Agreement; Prohibited Act means: (a) to directly or indirectly offer, promise or give to any person working for or engaged by the Authority a financial or other advantage

1 Screening Requirement Further comment or actions identified ☐ Consider the level of bribery risk associated with:—the country within which the prospective partner operates;—the type of business it is; and—the risks associated with both these variables. [Insert any comments or action points identified] ☐ Identify the latest Transparency International Corruption Perceptions Index rating for that country. [Insert any comments or action points identified] ☐ Make enquiries as to the relevant civil/criminal law of the particular country to identify any significant differences to UK law (eg legality of facilitation payments). [Insert any comments or action points identified] ☐ Make enquiries as to whether the potential partner has a reputation for bribery of if they have ever been investigated, prosecuted, convicted or debarred for bribery offences. [Insert any comments or action points identified] ☐ Consider whether reciprocal anti-bribery agreements or 'boilerplate' clauses have been exchanged or incorporated into your contracts. [Insert any comments or action points identified] ☐ Consider whether licences or certificates have to be obtained in another country, and if so, whether:—you have been provided with details of fees payable to the department or officer responsible

This Checklist covers the key considerations when formulating a strategy to combat counterfeiting and piracy. This Checklist should be used alongside Practice Note: Anti-counterfeiting and anti-piracy—strategy. Has the extent of the problem been assessed? Have the following people been consulted? • in-house personnel who have close involvement with the marketplace, including customer services staff who handle consumer complaints • external investigators tasked with assessing the level of counterfeit products in particular marketplaces (both online and in-stores) and making test purchases • agencies such as Trading Standards and HMRC/Border Force • internet service providers and website operators in respect of targets who appear to be predominantly operating online In some cases, employees or members of the public will notice counterfeit goods in shops, market stalls, at events or on holiday and will voluntarily notify the rights holder of such sightings. Has the following key information been identified? • territories most affected • products most affected • health and safety issues • level of risk to consumers and brand value • key perpetrators • any other trends Has

The purpose of an anti-counterfeiting and anti-piracy strategy Many brand owners and other IP right holders face an uphill struggle when it comes to preventing counterfeiting and piracy activities in the UK and abroad. In order to avoid wasting time and costs, it is important to devise a clear anti-counterfeiting and anti-piracy strategy which sets out priorities in the context of a defined budget. However, flexibility is also key as right holders may face an unexpected counterfeiting or piracy crisis and should have reserve capacity to deal with such instances. This Practice Note provides guidance on the issues to consider and steps to take when tasked with tackling identified instances of counterfeiting and piracy. Since these terms do not have universally accepted definitions, they are used in this Practice Note to denote acts of trade mark infringement (counterfeiting), copyright infringement (piracy) and, in certain scenarios, design infringement, which constitute criminal offences as well as attracting civil liability. In this Practice Note, the word ‘target’ is used to refer to counterfeiters and pirates alike. This Practice Note does not detail