Policy statement

It is the policy of Step Associates to conduct business in an honest and ethical manner. As
part of that, the Firm 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 implementing and enforcing effective systems to
counter bribery.

Purpose

The Firm 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.

Scope and applicability

• This policy applies to all individuals working for or on behalf of the Firm 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 Firm, (collectively referred to as Workers in this policy).
• In this policy, Third Party means any individual or organisation that Workers come into contact with during the course of work and the running of the Firm’s business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political
  parties.

What is bribery?

• A bribe is an inducement or reward offered, promised or provided in order to
  improperly gain any commercial, contractual, regulatory or personal advantage,
  which may constitute an offence under the Act, namely:
• giving or offering a bribe;
• receiving or requesting a bribe; or
• bribing a foreign public official.
• The Firm may also be liable under the Act if it fails to prevent bribery by an
  associated person (including but not limited to Workers) for the Firm’s benefit.

Gifts and hospitality

• This policy does not prohibit normal and appropriate gifts and hospitality (given and
  received) to or from Third Parties unless otherwise specifically stated. However, 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 (the Overriding Principles),
  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; and
• in the case of gifts, they must not be offered to, or accepted from,
  government officials or representatives, politicians or political parties,
  without the prior approval of either the Firm’s Anti-Bribery Compliance
  Partner or the Compliance Officer for Legal Practice (COLP) or Compliance
  Officer for Finance and Administration (COFA).
• The Firm appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.
• Gift limits of up to £50 in value to an employee is acceptable.

What is not acceptable?

• It is not acceptable for any Worker (or someone on their behalf) to:
• give, promise to give, or offer, a payment, gift or hospitality with the
  expectation or hope that they or the Firm will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
• give, promise to give, or offer, a payment, gift or hospitality to a government
  official, agent or representative to facilitate or expedite a routine procedure;
• accept payment from a Third Party where it is known or suspected that it is
  offered or given with the expectation that the Third Party will improperly
  obtain a business advantage;
• accept a gift or hospitality from a Third Party where it is known or suspected
  that it is offered or provided with an expectation that a business advantage
  will be improperly provided by the Firm in return;
• threaten or retaliate against another Worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
• engage in any activity that might lead to a breach of this policy.

Facilitation payments and kickbacks

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such
as small, unofficial payments made to secure or expedite a routine government action by a
government official, or payments made in return for a business favour or advantage.

Charitable donations and sponsorship.

The Firm only makes charitable donations and provides sponsorship that are legal and
ethical under local laws and practices and which are in accordance with the Firm’s internal
policies and procedures.

Record keeping

We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.

Responsibilities and raising concerns

• The prevention, detection and reporting of bribery and other forms of corruption are
  the responsibility of all those working for us or under our control. All Workers are
  required to avoid any activity that might lead to, or suggest, a breach of this policy.
• Workers are required to notify the Firm as soon as possible if it is believed or
  suspected that a conflict with this policy has occurred, or may occur in the future, or
  if they are offered a bribe, are asked to make one, suspect that this may happen in
  the future, or believe that they are a victim of another form of unlawful activity.
• Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our
  contractual relationship with non-employee Workers if they breach this policy.
• If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with the Firm’s Anti-Bribery Compliance Partner, Tom Clark.

Training and communication

Training on this policy is provided for all Workers and our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors and business partners.

Monitoring and review

• The Firm monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and
  procedures are also subject to regular review to provide assurance that they are
  effective in countering any risks of bribery and corruption.
• All Workers are aware that they are responsible for the success of this policy and
  should ensure they use it to disclose any suspected danger or wrongdoing.