Anti-Bribery & Corruption Policy

Sterling Industries PLC and its Operating Companies will conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our dealings wherever we operate. We are committed to implementing and enforcing effective measures to counter bribery.

The Policy

Sterling Thermal Technology prohibits – the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from – any person or company, wherever they are situated and whether they are a public official or body or private person or company by – any individual employee, agent or other person or body acting on Sterling’s behalf in order to gain any commercial, contractual or regulatory advantage for Sterling in a way which is unethical, or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual. This policy is not meant to prohibit the following activities, provided they are customary, proportionate and properly recorded: normal and appropriate hospitality ceremonial gifts at special occasions fast-tracking a process when it is available to all on payment of a fee providing resources to assist the person or body to make the decision more efficiently provided it is for this purpose only

Responsibility

This policy is applicable to all directors and employees of Sterling Industries PLC and its Operating Companies.
The prevention, detection and reporting of bribery is the responsibility of all Sterling’s employees. Suitable channels of communication by which employees or others can report confidentially any suspicion of bribery will be maintained through whistleblowing procedures.

Sterling will investigate seriously any actual or suspected breach of this policy, or the spirit of this policy. Employees may be subject to disciplinary action.

Anti-Bribery & Corruption Policy
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