Anti-bribery policy


Bribery is, in the conduct of the Company’s business, the offering or
accepting of any gift, loan, payment, reward or advantage for personal
gain as an encouragement to do something which is dishonest, illegal
or a breach of trust.

Bribery is a criminal offence. The Company prohibits any form of
bribery. We require compliance, from everyone connected with our
business, with the highest ethical standards and anti-bribery laws
applicable. Integrity and transparency are of utmost importance to us
and we have a zero tolerance attitude towards corrupt activities of
any kind, whether committed by Hyperreal Enterprises Ltd’s employees
or by third parties acting for or on behalf of Hyperreal Enterprises Ltd.


The purpose of this policy is to convey to all employees and
interested parties of Hyperreal Enterprises Ltd the rules of the
Company in relation to our unequivocal stance towards the eradication
of bribery and our commitment to ensuring that Hyperreal Enterprises
Ltd conducts its business in a fair, professional and legal manner.


It is a criminal offence to:

• offer a bribe
• accept a bribe
• bribe a foreign official
• as a commercial organisation, to fail to prevent a bribe.

You should be aware that if you are found guilty by a court of
committing bribery, you could face up to 10 years in prison and/or an
unlimited fine. The Company could also face prosecution and be liable
to pay a fine.

Definitions of bribery and corruption

Corruption is the misuse of office or power for private gain. Bribery
is a form of corruption which means in the course of business giving
or receiving money, gifts, meals, entertainment or anything else of
value as an inducement to a person to do something which is dishonest
or illegal.


This policy applies to all employees of Hyperreal Enterprises Ltd,
regardless of seniority or site. It also extends to anyone working for
or on our behalf eg those engaged by us on a self-employed basis or an
agency arrangement.

We will encourage the application of this policy where our business
involves the use of third parties eg suppliers; contractors.


It is prohibited, directly or indirectly, to offer, give, request or
accept any bribe ie gift, loan, payment, reward or advantage, either
in cash or any other form of inducement, to or from any person or
company in order to gain commercial, contractual or regulatory
advantage for the Company, or in order to gain any personal advantage
for an individual or anyone connected with the individual in a way
that is unethical.

It is also prohibited to act in the above manner in order to influence
an individual in his capacity as a foreign public official. You should
not make a payment to a third party on behalf of a foreign public

If you are offered a bribe, or a bribe is solicited from you, you
should not agree to it unless your immediate safety is in
jeopardy. You should immediately contact Joseph Corneli, Director, so
that action can be taken if considered necessary. You may be asked to
give a written account of events.

If you, as an employee or person working on our behalf, suspect that
an act of bribery, or attempted bribery, has taken place, even if you
are not personally involved, you are expected to report this to
contact Joseph Corneli, Director. You may be asked to give a written
account of events.

Appropriate checks will be made before engaging with suppliers or
other third parties of any kind to reduce the risk of our business
partners breaching our anti- bribery rules.

The Company will ensure that all of its transactions, including any
sponsorship or donations given to charity, are made transparently and
legitimately.  Hyperreal Enterprises Ltd takes any actual or suspected
breach of this policy extremely seriously and will carry out a
thorough investigation should any instances arise.We will uphold laws
relating to bribery and will take disciplinary action against any
employee, or other relevant action against persons working on our
behalf or in connection with us, should we find that an act of
bribery, or attempted bribery, has taken place. This action may result
in your dismissal if you are an employee, or the cessation of our
arrangement with you if you are self-employed, an agency worker,
contractor etc.

Staff are reminded of the Company’s whistleblowing policy which is
available in the employee handbook, or upon request.

Gifts and hospitality

We realise that the giving and receiving of gifts and hospitality
where nothing is expected in return helps form positive relationships
with third parties where it is proportionate and properly
recorded. This does not constitute bribery and consequently such
actions are not considered a breach of this policy.  Gifts include
money; goods (flowers, vouchers, food, drink, event tickets when not
used in a hosted business context); services or loans given or
received as a mark of friendship or appreciation.

Hospitality includes entertaining; meals or event tickets (when used
in a hosted business context) given or received to initiate or develop
relations. Hospitality will become a gift if the host is not present.

No gift should be given nor hospitality offered by an employee or
anyone working on our behalf to any party in connection with our
business without receiving prior written approval from Joseph Corneli,
Director. Similarly, no gift nor offer of hospitality should be
accepted by an employee or anyone working on our behalf without
receiving prior written approval from Joseph Corneli, Director.

A record will be made of every instance in which gifts or hospitality
are given or received.

As the law is constantly changing, this policy is subject to review
and the Company reserves the right to amend this policy without prior