Overview

This policy applies to all employees of CRE unless stated otherwise, including subsidiaries.

Anyone who is employed by, or performs services for, or on behalf of, CRE anywhere in the world, in any capacity, including agency workers and contractors, are bound by this policy. Additionally, any persons employed by, or performing services for, or on behalf of, CRE outside of the UK may also be required to comply with local laws in relation to Anti-bribery/corruption as well as this policy.

Intermediaries and other business partners are expected to act ethically and may be required to comply with this policy in all their dealings with or for CRE.

This policy does not form part of contracts of employment. CRE reserves the right to amend this policy from time to time.

Policy Statement

The purpose of this policy and the supporting guide is to set standards of behaviour that minimise the risk of bribery for CRE and those employed by or performing a service for or on behalf of CRE. The principles underpinning this are the same in every country in which we operate, regardless of business sector, local customs and practices.

Any breach of this policy, or any procedure implementing it, will be treated as a very serious matter by CRE and may result in disciplinary action, up to and including termination of employment and reporting to the appropriate authorities.

Complying with the policy will help to protect people from unlimited fines and a potential prison sentence of up to ten years, as well as protecting CRE from potentially unlimited fines and significant reputational damage.

Bribery and Corruption

What is bribery?

Bribery is: Promising, offering, giving, requesting or accepting, whether directly or through a third party, ANY ADVANTAGE to induce or reward behaviour that is improper (illegal, unethical or a breach of duty).

Even if a bribe is turned down or fails to have the intended effect, it is still a bribe.

CRE has a zero tolerance policy towards bribery and corruption.

Bribery could be committed by:

• Any employee of CRE regardless of seniority or grade anywhere in the world; or
• Any other person performing services on behalf of CRE anywhere Anti-Bribery Policy in the world (i.e. third parties such as agents, intermediaries, contractors and suppliers).

Reporting Concerns

If an employee knows that bribery or corruption has taken place, or they have any suspicions that it has taken place or may do so, anywhere within, or related to, CRE, they must immediately report this.

CRE is committed to ensuring that employees can report their concerns in complete confidence. All reports are taken very seriously and will be investigated accordingly. Retaliation, in any form, against a reporter is strictly prohibited.

Concerns should be raised in good faith and deliberately false claims will not be tolerated.

This policy is jointly owned and managed by CRE’s Managing Directors.

This version: January 2018