Anti-corruption and bribery policy.

It is the policy of QuantSpark to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

QuantSpark will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad.

Who must comply with this policy?

This policy applies to all persons working for QuantSpark or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

What is bribery?

"Bribe" means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

"Bribery" includes offering, promising, giving, accepting or seeking a bribe.

All forms of bribery are strictly prohibited. It is not acceptable for any Worker (or someone on their behalf) to:

• Give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received

• Accept any offer from a third party that they know, or suspect is made with the expectation that QuantSpark will provide a business advantage for them or anyone else

• Give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure

• Threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

Gifts and hospitality

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

We have specific internal policies and procedures which provide guidance to Workers as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below, namely that any gift or hospitality:

• Must not be made with the intention of improperly influencing a Third Party or Worker to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits

• Must comply with local law in all relevant countries

• Must be given in the name of the organisation, not in an individual’s name

• Must not include cash or a cash equivalent

• Must be appropriate in the circumstances

• Must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift

• Must be given openly, not secretly

Record keeping

Workers must declare on the Gift Register the details of all hospitality and gifts given or received above the value of £50.00.

Workers must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness.

Accounts must not be kept "off-book" to facilitate or conceal improper payments.

Raising a concern

Workers must notify their line manager or report in accordance with our Whistleblowing Policy should they be offered a bribe, are asked to make one, or if they suspect that any bribery, corruption or other breach of this policy has occurred or may occurred.

Contact Us

If you have any enquiries or if you would like to contact us, please contact us centrally by any of the methods below.

• Contact name: Adam Hadley

• Telephone: +44 (0)20 8075 7677

• Email: enquiries@quantspark.com

• Post: QuantSpark, 230 Blackfriars, London, SE1 8NW