Anti-Bribery and Corruption

1.1 For the purposes of this policy the expressions ‘adequate procedures’ and ‘associated with’ shall be construed in accordance with the Bribery Act 2010 and guidance published under it.

1.2 Bribery Act 2010 and associated guidance published by the Secretary of State for Justice under the Bribery Act 2010 and all other applicable United Kingdom laws, legislation, statutory instruments and regulations in relation to bribery or corruption and any similar or equivalent laws in any other relevant jurisdiction.

1.3 IAM shall ensure that it and each person referred to in clauses 1.4.1 to 1.4.3 (inclusive) does not, by any act or omission, breach of any Bribery Laws nor do they place any customer IAM contracts with in breach.

1.4 IAM shall comply with all applicable Bribery Laws and ensure that it has in place adequate procedures to prevent any breach of this policy and ensure that:

1.4.1 all of its personnel and all direct and indirect subcontractors, suppliers, agents and other intermediaries of it;

1.4.2 all others associated with it; and

1.4.3 each person employed by or acting for or on behalf of any of those persons referred to in clauses 1.5.1 and/or 1.5.2 so comply.

1.5 Without limitation to clause 1.5, IAM shall not make or receive any bribe (which term shall be construed in accordance with the Bribery Act 2010) or other improper payment or advantage, or allow any such to be made or received on its behalf, either in the United Kingdom or elsewhere, and will implement and maintain adequate procedures to ensure that such bribes or improper payments or advantages are not made or received directly or indirectly on its behalf.

1.6 Any breach of any of the requirements in this policy shall be deemed a material breach of any contract, made with a customer, that is not remediable and shall entitle the contracting party to immediately terminate a contract with IAM by providing the relevant notice.