The Sysop Bribery & Corruption Policy

Bribery and corruption is, unfortunately, a feature of corporate and public life in many countries across the world. Governments, businesses and non-governmental organisations such as Transparency International are working together to tackle the issue but despite our collective efforts eradicating all forms of bribery and corruption will take time.

Sysop therefore has a clear policy and we support our employees to make decisions in line with our stated position.

Our corporate conduct is based on our commitment to acting professionally, fairly
and with integrity. Sysop does not tolerate any form of bribery and corruption.

PURPOSE
The purpose of this policy is to set out the responsibilities of Company functions and business units in observing and upholding our position on bribery and corruption. In developing this policy we have made reference to the ‘Business Principles for Countering Bribery’ published by Transparency International.

SCOPE
This policy applies to Sysop employees (staff, contract and temporary) and
extends to all our majority owned business dealings and transactions in all
countries in which we or our subsidiaries and associates operate.
Where we have a minority interest we will encourage the application of this policy amongst our business partners including contractors, suppliers and joint venture partners.
This policy should be implemented in conjunction with the guidance on giving
and accepting gifts and hospitality within the Company Guide to Sound Business
Practice. Employees should also read the Company policy on gifts and hospitality.

POLICY
Our Company Business Principles set out our commitment to operate responsibly
wherever we work in the world and to engage with our stakeholders to manage
the social, environmental and ethical impact of our activities in the different
markets in which we operate.
Our first principle, ‘integrity in corporate conduct’, states that Sysop does not
engage in bribery or any form of unethical inducement or payment including
facilitation payments and ‘kickbacks.’ All employees are required to avoid any
activities that might lead to, or suggest, a conflict of interest with the business of the Company. Employees must declare and keep a record of hospitality or gifts
accepted or offered, which will be subject to managerial review. We do not make
direct or indirect contributions to political parties.
We will uphold laws relevant to countering bribery and corruption in all the
jurisdictions in which we operate, particularly laws that are directly relevant to
specific business practices.

RESPONSIBILITIES
The Managing Director is the main board director with primary responsibility
for implementing this policy and for reporting annually to the Sysop Board of
Directors. If any instance of bribery
or corruption is identified, we will take remedial steps immediately.

TRAINING AND COMMUNICATIONS
We will communicate this policy and relevant guidance to employees across the
Company, through our established internal communication channels. We will also
communicate this policy to our suppliers, contractors and business partners and
wider stakeholders. Managers, employees and agents will receive relevant
training on how to implement this policy in the scope of their employment with the Company.

RAISING CONCERNS AND SEEKING GUIDANCE
Employees are encouraged to raise concerns about any instance of malpractice
at the earliest possible stage.
Employees will receive the full support of the Company when refusing to pay a bribe, even if it may result in the Company losing business.

MONITORING AND REVIEW
The Sysop Board will review the implementation of this policy in
respect of its suitability, adequacy and effectiveness and make improvements as
appropriate.

INTERNAL CONTROLS AND AUDIT
Sysop will establish feedback mechanisms in order to maintain accurate
records - available for inspection - which properly and fairly document all financial transactions. Internal control systems will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.