Anti-Bribery Policy

It is WMT’s policy to carry out business fairly, honestly and openly both at home and abroad. As such we have a zero-tolerance approach towards bribery in any part of our business. Bribery is defined as a promise, offer or gift (financial or otherwise) to bring about the improper performance of a function or activity.

Examples of this would be offering a potential client a gift on the condition they do business with us, or a client offering a WMT team member a gift, on the basis that we will reduce the price of our service to them. To meet this commitment, the firm has the following systems in place to counter bribery:

• Periodical risk assessments will be documented to assess the levels of risk the firm is exposed to in its business, particularly the Accounts and Tax Teams
• An entertainment and expenses policy that sets out that only reasonable hospitality, entertaining and gift giving expenses will be reimbursed by the firm, and that such expenditure should not induce either party to contract
• All new employees will receive, as part of their induction, training on preventing, detecting and reporting bribery
• All employees are expected to undertake anti-money laundering training as and when requested by the firm, and in line with statutory obligations.

If a WMT team member is asked to accept, or offer a bribe, they must report this immediately to the Money Laundering Reporting Officer. The firm values a proactive anti-bribery stance by any employee.

As we take our obligations to prevent bribery being committed very seriously, any breach of our anti-bribery policy or procedures will be considered to be gross misconduct and may result in dismissal. Where a WMT team member has been involved in, or suspected of involvement in bribery that is not connected with this firm, this may still affect the individual’s suitability for on-going employment with WMT.

Gift Giving and Receiving

The exchange of small gifts and modest business courtesies between business partners is a common part of doing business. This practice, however, can sometimes create conflicts of interest or the appearance of wrongdoing. At WMT LLP, we cannot allow the exchange of gifts and entertainment to influence or appear to influence our independent business judgment or the independent business judgment of the companies with which we do business.

Acceptable Gifts

The following are examples of gifts that are usually acceptable:

• A box of chocolates, fruit basket or modest hamper
• A reasonable business meal at a local restaurant
• Promotional items of small value, such as coffee mugs, pens or golf shirts with company logos.

Unacceptable Gifts

WMT LLP employees are prohibited from giving or accepting gifts or entertainment that are:

• Illegal
• Offered in exchange for something in return
• Sexually oriented or otherwise inappropriate
• Offered to a government official without the prior written approval of a Partner.

Gifts Received

Team members are required to declare in writing to a Partner all gifts received in the course of business. Team members will not be allowed to retain these gifts without the prior approval of a Partner. Team members must not accept or agree to receive any gift if they know or suspect it is intended as a bribe. Cash or equivalent gifts are strictly prohibited. Under no circumstances are team members permitted to request gifts of any kind from clients, potential clients, suppliers or any other third party in the course of business.

Gifts to Third Parties

Team members are prohibited from offering, promising or giving gifts to clients, potential clients, suppliers or any other third party in the course of business without the prior permission of a Partner. Permission will only be given if, in the circumstances, the gift is reasonable in nature, value and timing. Cash or equivalent gifts are strictly prohibited. Where the giving of a gift is permitted, it must be given openly and not overly frequently.

Hospitality Guidance

A WMT team member may offer, promise or give hospitality in the name of the firm providing all the following are complied with:

• A partner has authorised the team member to do so
• It is reasonable in nature, value and timing
• It is not promised, offered or given to influence a third party to enter into business with us or to give us a business advantage
• It is given openly
• It does not occur overly frequently between the parties.

A WMT team member may accept hospitality providing it is proportionate, appropriate and justifiable in the circumstances. Team members must ensure that by accepting hospitality they do not place, potentially place, or give the appearance of placing the firm in a position where a business advantage is expected to be given by us in return. Team members must not accept hospitality where they know, believe or suspect that it is intended as a bribe. Under no circumstances are team members permitted to request hospitality in the course of business.

Where hospitality is offered, promised, given or accepted details of this must be reported to a partner. This will be monitored by the Money Laundering Reporting Officer and the provision and acceptance of hospitality will be kept under review.