Anti-Bribery and Corruption Policy

Introduction

Wheatfromchaff Ltd (trading as CrowdRating.co.uk) values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:

 

The Policy
Wheatfromchaff Ltd prohibits the Board of Directors:
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 consultant, agent or other person or body acting on the Board of Directors behalf

in order to 
gain any commercial, contractual or regulatory advantage for the Board of Directors 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

Further Clarification
The Board of Directors recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Partnership or of the person or body employing or contracting with them or whom they represent.

This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded

 

Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the Director with responsibility for this policy before proceeding. If necessary, guidance should also be sought from the Compliance Officer .

Consultants and Principles Responsibility within Wheatfromchaff Ltd

The prevention, detection and reporting of bribery is the responsibility of all personnel.  Suitable channels of communication by which personnel or others can report confidentially any suspicion of bribery will be maintained via the Anti-Corruption Reporting procedures.Useful resource: www.transparency.org.uk for the Transparency Index

A fuller Policy and Procedures outlining all the Principals of the Act can be requested from the Compliance Officer by emailing  enquiries@crowdrating.co.uk.

Disclaimer

Your capital is at risk when you invest in shares and debt securities. You can lose some or all of your money and may not be able to realise your investment. Therefore you should should never invest more than you can afford to lose. If in doubt about the suitability or tax implications of any investment, please seek independent financial advice. 

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Wheatfromchaff does not accept any liability whatsoever for any direct or consequential loss however so arising, directly or indirectly, from any use of this report nor its contents. Investors may receive back less that they invested as investments may fall as well as rise in value. Investors should obtain independent advice based on their own circumstances before making investment decisions. By accepting this report you agree to be bound by the foregoing limitations.

The Ratings we publish have been approved and issued at Financial Promotions in the United Kingdom by Wheatfromchaff in the United Kingdom who is Authorised and Regulated by the Financial Conduct Authority FRN: 751017. Wheatfromchaff Limited registered office is Kilver Court, Kilver Street, Shepton Mallet, Somerset, BA4 5NF and telephone number +44 (0) 1749 347 577. Telephone calls may be recorded. VAT No: 214 0196 49

© Wheatfromchaff Ltd All Rights Reserved February 2017