Anti-Corruption & Bribery Policy

Policy statement. It is the policy of Casual Films (“the Company”) to conduct business in an honest and ethical manner. The Company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and to implementing and enforcing effective systems to counter bribery.

Purpose. The Company will uphold all laws relevant to countering bribery and corruption in every jurisdiction 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.

Scope and applicability. This policy applies to all individuals working for or on behalf of the Company at all levels and grades — whether permanent, fixed-term or temporary, and wherever located — including consultants, contractors, seconded staff, Casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of the Company (collectively, Workers). Third Party means any individual or organisation Workers come into contact with during the course of work, including actual and potential clients, intermediaries, referrers, suppliers, distributors, business contacts, agents, advisers, government and public bodies, politicians and political parties.

What is bribery? A bribe is an inducement or reward offered, promised or provided to improperly gain any commercial, contractual, regulatory or personal advantage — namely giving or offering a bribe; receiving or requesting a bribe; or bribing a foreign public official. The Company may also be liable if it fails to prevent bribery by an associated person for the Company’s benefit.

Gifts and hospitality. This policy does not prohibit normal and appropriate gifts and hospitality to or from Third Parties. Any gift or hospitality must not be made to improperly influence anyone to obtain or retain business or advantage; must comply with local law; must not include cash or a cash equivalent; must be appropriate in type, value and timing; must be given openly, not secretly; and, in the case of gifts, must not be offered to or accepted from government officials, politicians or political parties without prior approval. The test is whether, in all the circumstances, the gift or hospitality is reasonable and justifiable — the intention behind it should always be considered.

What is not acceptable. It is not acceptable for any Worker (or someone on their behalf) to: give, promise or offer a payment, gift or hospitality expecting a business advantage in return, or as a reward for one already given; make such an offer to a government official to facilitate a routine procedure; accept payment where it is suspected to be offered for improper advantage; accept a gift or hospitality where a business advantage is expected in return; threaten or retaliate against a Worker who refuses to commit a bribery offence or raises concerns; or engage in any activity that might breach this policy.

Facilitation payments and “kickbacks”. We do not make, and will not accept, facilitation payments or kickbacks of any kind.

Charitable donations and sponsorship. The Company only makes charitable donations and provides sponsorship that are legal and ethical under local laws and in accordance with our internal policies.

Record keeping. We keep appropriate financial records and internal controls that evidence the business reason for gifts, hospitality and payments made and received.

Responsibilities and raising concerns. Prevention, detection and reporting of bribery are the responsibility of everyone working for us or under our control. Workers must notify the Company as soon as possible if they believe or suspect a conflict with this policy has occurred or may occur, or if they are offered a bribe or asked to make one. Any employee who breaches this policy may face disciplinary action up to dismissal for gross misconduct. Any Third Party aware of activity that might breach this policy should raise concerns with the Company’s CFO at edward@casualfilms.com.

Training and communication. Training on this policy is available for all Workers, and our zero-tolerance approach is communicated to clients, suppliers, contractors and business partners where appropriate.

Monitoring and review. The Company monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, making improvements as soon as they are identified.