ANTI-BRIBERY & ANTI-CURRUPTION POLICY

1. What Does This Policy Cover?

1.1 This anti-bribery policy exists to set out the responsibilities of NOTEBOOK CONSTRUCTION LTD, and  those who work for us in regard to observing and upholding our zero-tolerance position on bribery and corruption.

1.2 It also exists to act as a source of information and guidance for those working for NOTEBOOK CONSTRUCTION LTD It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

2. Policy statement

2.1. NOTEBOOK CONSTRUCTION LTD is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. NOTEBOOK CONSTRUCTION LTD has zero-tolerance for  bribery and corrupt activities. NOTEBOOK CONSTRUCTION LTD are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

2.2. NOTEBOOK CONSTRUCTION LTD will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which NOTEBOOK CONSTRUCTION LTD operate. NOTEBOOK CONSTRUCTION LTD are bound by the laws of the UK, including the Bribery Act 2010, regarding our conduct both at home and abroad.

2.3. NOTEBOOK CONSTRUCTION LTD recognises that bribery and corruption are punishable by up to ten  years of imprisonment and a fine. If the company is discovered to have taken part in corrupt activities, it may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to its reputation. It is with this in mind that NOTEBOOK CONSTRUCTION LTD commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

3. Who is covered by the policy?

3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). 

3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum.

4. Definition of Bribery

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

4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

4.3 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.

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or  through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They  must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager. (Dashnor Troci)

5. What is and what is NOT acceptable

5.1 This section of the policy refers to 4 areas:

• Gifts and hospitality.
• Facilitation payments.
• Political contributions.
• Charitable contributions.

5.2 Gifts and hospitality

NOTEBOOK CONSTRUCTION LTD accepts normal and appropriate gestures of hospitality and goodwill (whether given to / received from third parties) so long as the giving or receiving of gifts meets the following requirements:

1.  It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a   business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
2.  It is not made with the suggestion that a return favour is expected.
3.  It is in compliance with local law.
4.  It is given in the name of the company, not in an individual’s name.
5.  It does not include cash or a cash equivalent (e.g., a voucher or gift certificate).
6.  It is appropriate for the circumstances (e.g., giving small gifts around Christmas or as a small thank you to a company for   helping with a large project upon completion).
7.  It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
8.  It is given/received openly, not secretly.
9.  It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
10.  It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).
11.  It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.

5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.

5.4. NOTEBOOK CONSTRUCTION LTD recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.

5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should  always be disclosed. 

5.6 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.

5.7 Facilitation Payments and Kickbacks. NOTEBOOK CONSTRUCTION LTD does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. NOTEBOOK CONSTRUCTION LTD recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

5.8 NOTEBOOK CONSTRUCTION LTD does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically, made in exchange for a business favour or advantage.

5.9 NOTEBOOK CONSTRUCTION LTD recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their  family’s personal security at risk. Under these circumstances, the following steps must be taken:

1. Keep any amount to the minimum.
2. Ask for a receipt, detailing the amount and reason for the payment.
3. Create a record concerning the payment.
4. Report this incident to your line manager.

5.10 Political Contributions. NOTEBOOK CONSTRUCTION LTD will not make donations, whether in cash, kind, or by any other means,  to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

5.11 Charitable Contributions. NOTEBOOK CONSTRUCTION LTD accepts (and indeed encourages) the act of donating to charities:– whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.

6. Employee Responsibilities

6.1 As an employee of NOTEBOOK CONSTRUCTION LTD you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.

6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.

6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. NOTEBOOK CONSTRUCTION LTD has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.

7. What happens if I need to raise a concern?

7.1 This section of the policy covers 3 areas:

1. How to raise a concern.
2. What to do if you are a victim of bribery or corruption.
3. Protection.

7.2 How to raise a concern. If you suspect that there is an instance of bribery or corrupt activities occurring in relation to NOTEBOOK CONSTRUCTION LTD, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, or the Managing Director.

7.3 NOTEBOOK CONSTRUCTION LTD will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.

7.4 What to do if you are a victim of bribery or corruption. You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

7.5 Protection. If you refuse to accept or offer a bribe or report a concern relating to potential act(s) of bribery or corruption, NOTEBOOK CONSTRUCTION LTD understands that you may feel worried about potential repercussions. NOTEBOOK CONSTRUCTION LTD will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

7.6 NOTEBOOK CONSTRUCTION LTD will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.

7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately.

8. Training and communication

8.1 NOTEBOOK CONSTRUCTION LTD will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.

8.2 NOTEBOOK CONSTRUCTION LTD’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third- parties at the outset of business relations, and as appropriate thereafter.

8.3 NOTEBOOK CONSTRUCTION LTD will provide relevant anti-bribery and corruption training to employees etc, where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti- bribery training where there is a potential risk of facing bribery or corruption during work activities.

9. Record keeping

9.1 NOTEBOOK CONSTRUCTION LTD will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given and understand that gifts and acts of hospitality are subject to managerial review.

10. Monitoring and reviewing

10.1 NOTEBOOK CONSTRUCTION LTD ’s compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.

10.4 This policy does not form part of an employee’s contract of employment and NOTEBOOK CONSTRUCTION LTD may amend it at any time so to improve its effectiveness at combatting bribery and corruption.

ANTI-SLAVERY & HUMAN TRAFFICKING POLICY

1. Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person, with a view to that person being exploited. Modern Slavery is a crime and a violation of fundamental human rights. 

2. This policy applies to all persons working within NOTEBOOK CONSTRUCTION LTD and any person working on behalf of NOTEBOOK CONSTRUCTION LTD in any capacity. This includes employees at all levels, Directors, Managers, labour only sub contracted staff, Agency workers, agents, sub-contractors, and suppliers.

3. NOTEBOOK CONSTRUCTION LTD strictly forbids the use of modern slavery and human trafficking in its operations and in its supply chain. NOTEBOOK CONSTRUCTION LTD have and will continue to be committed to implementing controls aimed at ensuring that modern slavery is not taking place anywhere within the organisation or in any of the supply chains. NOTEBOOK CONSTRUCTION LTD expect that their suppliers will hold their own suppliers to the same high standards.

NOTEBOOK CONSTRUCTION LTD Commitments.

4. NOTEBOOK CONSTRUCTION LTD, is a company that expects everyone working with us or on our behalf, to support and uphold the following measures to safeguard against modern slavery:

1. There will be zero tolerance to modern slavery in NOTEBOOK CONSTRUCTION LTD and its supply chains.
2. The prevention, detection and reporting of modern slavery in any part of the organisation or supply chain is the responsibility of all those working for us or in the supply chain. Workers must not engage in, facilitate or fail to report any operations that might lead to, or suggest, a breach of this policy.
3. NOTEBOOK CONSTRUCTION LTD are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in operations and supply chain.
4. We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers, requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
5. Consistent with our risk-based approach we may require:     
                                                                            
   i. Employment and recruitment agencies and other third parties supplying workers to our organisation, to confirm their compliance with our Code Of Conduct.
   ii. Suppliers engaging workers through a third party to obtain that third partie's agreement to adhere to the code.
   
   
6. As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
7. If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated, and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

ENVIRONMENTAL POLICY STATEMENT

The understanding of the need for the protection of the environment forms an integral part of the NOTEBOOK CONSTRUCTION LTD business philosophy. Under the Environmental Duty of Care, the Company is committed to protecting the environment and believe that the Company has a responsibility not to compromise the ability of future generations to sustain their needs. 

In confirming our commitment to the protection of the environment, the requirements of environmental legislation applicable to our activities, are minimum working standards and where appropriate we aim to better them using best available technology and techniques.

Environmental Protection will have equal status to considerations for Health, Safety and Production Quality and the company shall adopt the principal of continuous improvement and set targets and objectives for performance. 

We will seek to reduce, whenever practicable, our consumption of non-renewable resources, and will seek to select materials which have minimum negative impact on the environment. 

Responsibility for the Environmental Policy and supporting statement lies with the Board of Directors. The Environmental Policy will be brought to the attention of all employees and will be reviewed annually to assess its effectiveness, compliance with environmental law and that it reflects company changing needs and circumstances. 

Whilst recognising the fundamental responsibility of the Company and its employees in relation to environmental protection, particular attention will be paid to the following areas: 

Waste Management - waste will be kept to a practical minimum, compatible with best trade practises. Only licensed waste contractors and licenced transfer stations will be utilised for the disposal of company generated waste. Compliance with the requirements of the Hazardous Waste Regulations 2005 shall be maintained at all times. 

Flora and Fauna in and Around Project Locations - Every effort shall be made to minimise the effects of the company activity on the flora and fauna within and around project sites. Specific tender stage checks shall be carried out to establish site-specific conditions and the presence of any protected and or at-riskspecies. Where employed as a sub-contractor NOTEBOOK CONSTRUCTION LTD will conform to all environmental plans issued by them, and where no plan exists will apply NOTEBOOK CONSTRUCTION LTD policies.

Recycling - whenever practicable materials will be recycled throughout the company activity. 

Noise/Dust Light - will be suppressed, where safe and practical, to ensure that no nuisance is caused to neighbouring establishments or the public. 

Conservation of Energy - The site managers shall, where appropriate, introduce and monitor efficient and economic use of energy in the form of fuel, heating and lighting. 

Training - All relevant company employees shall be made aware of the objectives of this policy and the contribution expected from them. Employees with high-risk tasks shall be trained in the environmental aspects associated with those tasks. 

Legislative Compliance - Regular operational assessments shall be carried out to ensure compliance with the legislation and the application of best available practice in environmental protection. 

All employees are equally responsible for complying with the Environmental Policy and are encouraged to suggest improvements leading to a policy of continuous improvement. Sub-Contractors shall be encouraged to apply the principals of this policy but shall be required to ensure they comply with the minimum relevant legislation. 

EQUAL OPPORTUNITY POLICY STATEMENT

NOTEBOOK CONSTRUCTION LTD confirms its commitment to equality of opportunity in all areas of its work and in the workplace. All individuals will be treated in a fair and equal manner and in accordance with the law regardless of gender, marital status, race, religion, colour, age, disability or sexual orientation.

NOTEBOOK CONSTRUCTION LTD will not discriminate in any area of employment, or in the provision of its services to the public, clients and staff and accepts its responsibilities to comply with all relevant legislation including the Sex Discrimination Acts 1975 and 1986, the Equal Pay Act 1970, the Race Relations Act 1976, the Disability Discrimination Act 1995, and the Rehabilitation of Offenders Act 1975.

NOTEBOOK CONSTRUCTION LTD will ensure: 

• That no job applicant or employee receives less favourable treatment on the grounds of their Race, Sex, or Disability. 
• That no applicant or employee is placed at any disadvantage because of their Race, Sex, or Disability that is not justifiable in Law under the Race, Sex or Disability Discrimination Act. 

If you have a disability for the purposes of the Disability Discrimination Act, please notify your Supervisor / Manager so that reasonable adjustments can be considered.

The Company does not and will not tolerate any racist, sexist or disability harassment and anyone found to be acting in such a way will face disciplinary action that could include dismissal. Everyone has a duty to report any such behaviour to Management. 

It is the responsibility of all Managers and Supervisors of the NOTEBOOK CONSTRUCTION LTD to act in a fair and proper manner and in accordance with this Policy. Managers will ensure that the policy is properly applied. 

Anyone who feels that he or she has been subjected to unfair discrimination should take the matter up with the Managing Director or relevant Manager.

QUALITY POLICY STATEMENT 

NOTEBOOK CONSTRUCTION LTD recognises the importance that the quality of our service must be the future of our business. This is achieved through the implementation of the NOTEBOOK CONSTRUCTION LTD Quality Management  System (QMS), which is based upon the requirements of BS EN ISO 9001:2000. At this stage, the QMS does not comply with ISO9001 but is similar in its approach. 

The aim of our quality management system is to ensure that:

•  We deliver a quality service to maintain excellent customer relations.
•  Customer satisfaction remains inherent to our business.
•  Our customer’s requirements have been fully understood and met.
•  All work is carried out consistently to a defined standard.
•  We have the skills and resources to fulfil our customer requirements.
•  Our staff are fully trained and involved in quality improvement.
•  We strive to continuously improve our systems and procedures.
•  We only use services that meet our own quality assurance standards.
•  A professional approach to customer interface is always maintained.
•  Any complaints are dealt with efficiently and within an acceptable time period.

Quality is a degree of excellence, which is ever changing. Every member of staff is involved in managing how we can improve today, tomorrow, and long into the future.

From the smallest procedure to the largest contract, quality is our passport to customer satisfaction and to our future business, it’s the NOTEBOOK CONSTRUCTION LTD reputation.

The Company looks to improve the service it provides by ensuring regular reviews of its Quality Management System and by setting specific quality objectives. 

It is the responsibility of every employee to comply with the requirements of the Quality Management System and to improve its effectiveness.

The Company ensures that the staff have the necessary expertise and experience to achieve this, through its staff development programme. 

Commitment to this policy is fundamental to the Company's business and its continued success. Specific quality objectives are set on an annual basis, and all involved in the company will strive to achieve the goals and targets set