Introduction

Apex Displays Limited values its reputation and is committed to maintaining the highest level of ethical standards in the conduct ofits business affairs. The actions and conduct of the firm’s staff as well as others acting on the firm’s behalf are key to maintaining these standards.

The purpose of this document is to set out the firm’s policy in relation to bribery and corruption. The policy applies strictly to all employees, directors, agents, consultants, contractors and to any other people or bodies associated with Apex Displays Limited, within all regions, areas and functions.

Understanding and recognising bribery and corruption

Acts of bribery or corruption are designed to influence an individual in the performance of their duty and incline them to act in a way that a reasonable person would consider to be dishonest in the circumstances.

Bribery can be defined as offering, promising or giving a financial (or other) advantage to another person with the intention ofinducing or rewarding that person to act or for having acted in a way which a reasonable person would consider improper inthe circumstances. Corruption is any form of abuse of entrusted power for private gain and may include, but is not limited to, bribery.

Bribes are not always a matter of handing over cash. Gifts, hospitality and entertainment can be bribes if they are intended to influence a decision.

Penalties

The Bribery Act 2010 came into force on 1 July 2011. Under that Act, bribery by individuals is punishable by up to ten years’imprisonment and/or an unlimited fine. If the firm is found to have taken part in the bribery or is found to lack adequate procedures to prevent bribery, it too could also face an unlimited fine.

A conviction for a bribery or corruption related offence would have severe reputational and/or financial consequences for the firm.

Apex Displays Limited’s Policy

Apex Displays Limited will not tolerate bribery or corruption in any form. The firm prohibits the offering, giving, solicitation or theacceptance of any bribe or corrupt inducement, whether in cash or in any other form:

• Too or from any person or company wherever located, whether a public official or public body, or a private person or
• By any individual employee, director, agent, consultant, contractor or other person or body acting on the firm’s
• To gain any commercial, contractual, or regulatory advantage for the firm in any way which is unethical or to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

This policy is not intended to prohibit the following practices provided they are appropriate, proportionate and are properly recorded:

• Normal hospitality if it complies with the firm’s Corporate Entertainment
• Fast tracking a process which is available to all on the payment of a fee; and/or
• Providing resources to assist a person or body to decide more efficiently if it is for this purpose onl
• It may not always be a simple matter to determine whether a possible course of action is If you are in any doubt as to whether a possible act might be in breach of this policy or the law, the matter should be referred to your Head of Department. If necessary, guidance should also be sought from an external legal source.
• The firm will investigate thoroughly any actual or suspected breach of this policy, or the spirit of this Employees found to be in breach of this policy may be subject to disciplinary action which may ultimately result in their dismissal and possible referral to the authorities.

Key risk areas

Bribery can be a risk in many areas of the firm. Below are the key areas you should be aware of in particular:

• Excessive gifts, entertainment, and hospitality: can be used to exert improper influence on decision Gifts, entertainment, and hospitality are acceptable provided they fall within the Apex Displays Limited Expenses Policy.
• Facilitation payments: are used by businesses or individuals to secure or expedite the performance of a routine or necessaryaction to which the payer has an entitlement as of The firm will not tolerate or excuse such payments being made.
• Reciprocal agreements: or any other form of ‘quid pro quo’ are never acceptable unless they are legitimate businessarrangements which are properly documented and approved by Improper payments to obtain new business, retain existing business or secure any improper advantage should never be accepted or made.
• Actions by third parties for which the firm may be held responsible: can include a range of people i.e., agents, contractors,and consultants, acting on the firm’s Appropriate due diligence should be undertaken before a third party isengaged. Third parties should only be engaged where there is a clear business rationale for doing so, with an appropriatecontract. Any payments to third parties should be properly authorised and recorded.
• Record keeping can be exploited to conceal bribes or corrupt practices. We must ensure that we have robust controls in place so that our records are accurate.

Employee responsibility and how to raise a concern

The prevention, detection and reporting of bribery or corruption is the responsibility of all employees throughout the firm. If youbecome aware or suspect that an activity or conduct which is proposed or has taken place is a bribe or corrupt, then you have a dutyto report this to HR or the Compliance Team. The company may then refer this as an internal HR issue or a breach of Law dependingon the circumstances.

Managing Director – Jarome Warrilow

Signature:

Date : 1 July 2024