Anti-Bribery, Anti-Corruption, Fraud and Modern Slavery Statement

General Statement

Guru Systems Ltd has a legal obligation to comply with all relevant legislation including the Bribery Act 2010, the Fraud Act 2006 and the Modern Slavery Act 2015.

It is our policy to conduct all of our business fairly, honestly, openly and ethically. We take a zero-tolerance approach to bribery, fraud, modern slavery and human trafficking. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. Guru Systems values its reputation for propriety and reliability.

Guru Systems will implement and enforce effective prevention systems. We will take all reasonable steps, in accordance with good industry practice, to prevent bribery, fraud, modern slavery and human trafficking by Guru (including its shareholders, members and directors) and its employees in connection with the receipt of monies from our clients and when dealing with suppliers.

Definitions

• Modern Slavery is the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation.
• Corruption is the abuse of entrusted power or position for private gain.
• Bribery is offering, promising, giving or accepting a financial or other advantage intended to coerce someone into acting illegally, unethically or unjustly, or rewarding them for doing so.
• The Fraud act 2006 identifies three types of fraud:
  ○ fraud by false representation
  ○ fraud by failing to disclose information
  ○ fraud by abuse of position.

Aims and objectives

Guru Systems will uphold all UK laws, statutes and regulations essential to:

• countering bribery and corruption, including the Bribery Act 2010 (including sections 1 (bribing another person), 2 (being bribed) or 6 Bribery of foreign public officials)).
• prevention of fraud and other forms of corruption, including the Fraud Act 2006.
• preventing modern slavery and human trafficking, including the Modern Slavery Act 2015.

Commitment

Guru Systems will:

• Communication: Ensure all staff understand their responsibilities under this policy and are clear on how to raise a concern. Breach of Guru Systems’ Anti-Bribery, Fraud and Modern Slavery Policy could result in disciplinary action.
• Recruitment: Undertake appropriate right to work checks.
• Investigation and record keeping: Investigate and log all reports of bribery, corruption, fraud, modern-slavery and human trafficking and assist the police and other appropriate authorities if engaged.
• Supply chain: Undertake appropriate checks as part of supply chain sourcing and ongoing management.
• Facilitation payments and kickbacks: Not make and will not accept facilitation payments or kickbacks of any kind.
• Guru will take all reasonable steps, in accordance with good industry practice, to prevent fraud by Guru (including its shareholders, members and directors) and its employees in connection with the receipt of monies from our clients and when dealing with suppliers.
• Gifts and hospitality: Set rules for making or receiving gifts and hospitality and ensure that logs are maintained.