Anti-Bribery Statement 2021/22

Ceba Solutions Ltd (the organisation) is committed to applying the highest standards of ethical conduct
and integrity in its business activities in the UK and overseas. Every employee and individual acting on
the organisation’s behalf are responsible for maintaining the organisation’s reputation and for conducting
company business honestly and professionally.

The organisation considers that bribery and corruption has a detrimental impact on business.
The organisation benefits from carrying out business in a transparent and ethical way and helping to
ensure that there is honest, open and fair competition across our industry. Where there is a level playing
field, the organisation can lead the market by delivering excellent products, services and solutions to
our customers across the catering industry.

Transparent, fair conduct helps to foster deeper relationships of trust between ourselves and our
business partners and customers. This is vital for the reputation and future growth of Ceba Solutions Ltd.

Ceba Solutions Ltd does not tolerate any form of bribery, whether direct or indirect, by, or of, its
employees, officers, agents or consultants or any persons or companies acting for it or on its behalf. The
board and senior management are committed to implementing and enforcing effective systems within the
organisation to prevent, monitor and eliminate bribery, in accordance with the Bribery Act 2010.

The organisation provides an anti-bribery policy outlining the organisation’s position on preventing and
prohibiting bribery and it is our intent to make this available on our website. The anti-bribery policy applies
to all employees, as well as agency workers, consultants and contractors [both in the UK and overseas].

All employees and other individuals acting for the organisation are required to familiarise themselves and
comply with the organisation’s anti-bribery policy.

A bribe is a financial advantage or other rewards that is offered to, given to, or received by an individual or
company (whether directly or indirectly) to induce or influence that individual or company to perform
public or corporate functions or duties improperly.

Employees and others acting for or on behalf of the organisation are strictly prohibited from making,
soliciting or receiving any bribes or unauthorised payments.

As part of its anti-bribery measures, Ceba Solutions Ltd is committed to transparent, proportionate,
reasonable and bona fide hospitality and promotional expenditure. Such expenditure must be authorised
in advance, by the Managing Director.

A breach of the organisation’s anti-bribery policy by an employee will be treated as grounds for
disciplinary action, which may result in a finding of gross misconduct, and immediate dismissal.

Employees and other individuals acting for the organisation should note that bribery is a criminal offence
that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited
fine for the organisation.

The organisation will not conduct business with service providers, agents or representatives that do not
support our anti-bribery objectives and reserves the right to terminate its contractual arrangements with
any third parties acting for, or on behalf of, the organisation with immediate effect where there is evidence
that they have committed acts of bribery.

The success of our anti-bribery measures depends on all employees, and those acting for the
organisation, playing their part in helping to detect and eradicate bribery. Therefore, all employees and
others acting for, or on behalf of Ceba Solutions Ltd are encouraged to report any suspected bribery in
accordance with the procedures set out in the anti-bribery policy.

The organisation will support any individuals who make such a report, provided that it is made in good
faith.

This policy will be reviewed and updated annually.