Anti-Bribery and Corruption Policy

This document is produced on behalf Zinc Work Limited (“Zinc”) a company incorporated and registered in England and Wales (company number is 10961635) with a registered address at Eastcastle House, 27-28 Eastcastle Street, London, United Kingdom, W1W 8DH on behalf of itself and any affiliates. 

This document is intended for all current employees, workers or contractors at Zinc.

Please make sure you read it carefully and if  you have any questions or concerns regarding this policy then please contact hamraj@zincwork.com. 

Zinc is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. 

Zinc has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate. 

Zinc is committed to ensuring compliance with any relevant regulations and laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. This includes, but is not limited to, the Bribery Act 2010.

All Zinc employees are required to undergo training in respect of this policy during their onboarding and then annually thereafter. Where it is deemed necessary those employees with a higher risk of being exposed to bribery (regardless of their seniority) may receive compulsory extra training on this policy. 

Zinc conducts internal audits to monitor compliance with the policy and its effectiveness. This may be conducted by an internal member of staff or we may outsource the work to an external auditor. 

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Bribery 

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so as to induce or influence an action or decision. 

Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law. 

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Policy

Zinc accepts normal and appropriate gestures of hospitality and goodwill (whether given or received to or from third parties) so long as:

• the giving or receiving of gifts is not intended to influence the person or persons to whom it is given
• it is not made with the suggestion that a return favour is expected
• it is in compliance with any local laws and regulations
• it is given in the name of a company and not an individual
• it is an appropriate type and value of gift taking into account the reason for giving the gift
• It is not given in secret
• It is not being given by, or on behalf of, any government official or representative, political party or politician. 

Even when falling within these boundaries all staff are required to disclose the receipt or donation of any gift to their line manager. Line managers may report this to Hamraj Gulamali in writing at hamraj@zincwork.com if they deem it necessary. 

Zinc employees are prohibited from accepting facilitation payments or kickbacks and must not make any donation, be it cash or otherwise, to a political party under the Zinc company name. 

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Charity

Zinc employees may receive and accept gifts from charities (so long as they comply with the policy above), however, all employees must be aware that charitable donations may be a mechanism through which bribery is facilitated or concealed. 

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Detection procedure

Where a Zinc employee is involved in, or suspected to be involved in, bribery there will be a thorough investigation into the circumstances giving rise to the event. Zinc reserves the right to put in place any type of disciplinary action that may be appropriate which includes involving the police (or relevant authorities) and dismissing the employee. 

If an employee is kept in their role during an investigation they will be entitled to weekly written updates about the status of said investigation. 

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