Anti-Bribery & Corruption Policy

The purpose of this policy is to state Innova Nano Jet Technologies position on bribery and corruption and to provide information and guidance on recognising and dealing with bribery and corruption.

This policy covers all employees including those on temporary and fixed term contracts, external resources, consultants, business partners and any other person or organisation who performs services for or on behalf of Innova Nano Jet Technologies Limited in any location.

Integrity is a key value to Innova Nano Jet Technologies Limited. It is Innova NanoJet Technologies Limited policy to maintain the highest standards of ethics in all of our business dealings. We are committed to conducting ourselves fairly, honestly and lawfully in all our business dealings and relationships. We have a zero tolerance approach to bribery and corruption. Innova Nano Jet Technologies Limited is bound by the laws of the UK, including the Bribery Act 2010 which governs our conduct in the UK.

A bribe is an inducement or reward offered, promised or provided in order to bring about the improper performance by another person of a relevant function or activity.

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Examples:

Offering a bribe

You offer the representative of a client a weekend away for him and his partner if the client agrees to award Innova Nano Jet Technologies Limited a contract.
This would be an offence as you are making the offer to influence an improper performance of the client's impartiality towards its suppliers. Innova Nano Jet Technologies Limited may also have committed an offence because the offer has been made to obtain business for the group. It may also be an offence for the client representative to accept your offer.

Receiving a bribe

A supplier offers you a ticket to watch your favourite football team and makes it clear that it could be a regular occurrence if we continue to do business with them. It is an offence for a supplier to make such an offer.
It would be an offence for you to accept the offer as it would be seen as influencing an improper performance of your impartiality and good faith towards our suppliers.

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From time to time, you may give or receive a gift that is meant to show friendship, appreciation or thanks to or from someone who does business with Innova Nano Jet Technologies Limited . Generally speaking, giving or accepting gifts of low monetary value such as corporate give-aways, consumables or other items of nominal value is acceptable provided you don't ask for the gift and as long as ti does not influence, or have the appearance of influencing, your objectivity or decision-making. As a general rule, if accepting a gift could cause you (or a reasonable person in your position) to feel an obligation, don't accept it.

Larger gifts are more likely to cause a conflict of interest. Accordingly, the advance approval of the Managing Director is required in order to give or accept more than €60 worth of gifts to or from a single source in any 12-month period.  Among the factors to be considered in determining the appropriateness of a gift over this amount will be whether the gift is customary in the particular industry concerned and openly given without any expectation or realisation of special advantage.

Corporate hospitality, such as business lunches, dinners, drinks, hospitality at a sports or social event or other meetings in a social context are not considered to be gifts if a significant purpose of the meeting is business-related and your participation is in the ordinary course of business and is usual and customary. This can be a tricky area. If you are given tickets to a sporting event for your personal use, this would be considered a gift. If you attend an event with customers, business partners or suppliers, it would ordinarily not be considered a gift unless this occurs with a frequency that suggests a business purpose is not valid. If you have any doubts about your participation in such events, they should be discussed with the Managing Director.

Innova NanoJet Technologies Limited understands that the practice of giving business gifts varies and what may be normal and acceptable to one may not be to another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable The intention behind the gift should always be considered. For example, there is a difference between accepting a' corporate gift' (such as a traditional mark of friendship between companies, which may sit on display in your office and a 'personal gift' (which you might take home or enjoy personally) that might have the appearance of influencing your objectivity or impartial judgement.

It is not acceptable for you (or someone on your behalf) to:

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• give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

• give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure;

• accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
  accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

• threaten or retaliate against another employee or person working on behalf of or representing Innova Nano Jet Technologies Limited who has refused to commit a bribery offence or who has raised concerns under this policy; or

• engage in any activity that might lead to a breach of this policy

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for Innova NanoJet Technologies Limited or under our control. All employees and other Innova NanoJet Technologies Limited representatives are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify the Managing Director as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business, you should report this immediately.

Any employee who breaches this policy will face disciplinary action, which could result ni dismissal for gross misconduct.

Innova Nano Jet Technologies Limited keep financial records and has appropriate internal controls in place to evidence the business reason for making payments to third parties.  Accordingly, you must ensure that all expenses claim relating to hospitality or gifts incurred by you on behalf of Innova Nano Jet Technologies Limited for the benefit of a third party are submitted in accordance with our expenses procedures and specifically record the reason for the expenditure. These expenses should be recorded as Hospitality, as appropriate.

In addition, you must declare and keep a written record of al gifts accepted above £60 or equivalent, which will be subject to managerial review. This does not apply to corporate hospitality unless the Managing Director decides that a particular invitation should be recorded

You are encouraged to raise concerns about any issue or suspicion of corruption at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, you should raise them with the Managing Director

Employees or those who are acting on behalf of Innova NanoJet Technologies Limited who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. Innova NanoJet Technologies Limited encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Innova NanoJet Technologies Limited is committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Managing Director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedure.

Training on this policy will form part of the induction process for al new employees. All existing employees will receive regular, relevant updates on how to implement and adhere to this policy.

Innova NanoJet Technologies Limited's Managing Director has approved and issued this policy as part of its overall responsibility for ensuring that Innova Nano Jet Technologies Limited complies with its legal and ethical obligations. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter. All employees and those who are acting for or on behalf of Innova NanoJet Technologies Limited have an obligation to notify third parties of this policy at the start of any business relationship.

We will monitor the effectiveness and review the implementation of this policy regularly. Any improvements identified will be made as soon as possible Employees and those who are acting for or on behalf of Innova NanoJet Technologies Limited are invited to comment on this policy and suggest ways in which it might be improved. This policy does not form part of any employee's contract of employment and it may be amended at any time.