This statement is made on behalf of all companies within the Vista Group and sets out the steps the Vista Group has taken, and continues to take, to ensure that bribery, fraud or corruption is not taking place within our business operations.

Policy Statement

• The Vista Group are firmly committed to conducting all its business in a legal and ethical manner. The group adopts a zero-tolerance approach to any form of bribery and corruption. We hold ourselves to high standards, in which we are committed in continuing to enforce effective systems which ensure we act professionally and with integrity in all facets of our business operations to counter the threat of bribery and fraud. The Vista Group has built a positive reputation for lawful and responsible business; a reputation we consider an extremely valuable asset to our businesses. Therefore, this policy is intended to provide a clear framework so that everybody, within and outside of the group, understands the systems in place, and the appropriate steps we take, for the group to act in a compliant and legal fashion.
• The Vista Group is committed to complying with all laws relating to anti-bribery, corruption, and fraud in all jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, regarding our conduct both at home and abroad. We recognise that bribery and corruption are punishable by up to ten years of imprisonment and a fine.
• If an employee is uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the board of directors.

Definition of Bribery

• Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.
• A bribe refers to any inducement, reward, or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage.
• An individual who is on the receiving end of (and accepts) a bribe, are also breaking the law
• Bribery is an illegal act. All employees and those connected to the group are forbidden from engaging in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as a distributor).

Who is covered by the Policy?

• In lien with the Bribery Act’s (2010) clarification in relation to the new laws on bribery, our anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, and or any other persons associated with the Vista Group (including third parties).
• In the context of this policy, third-party refers to any individual or organisations our group meets and works with. The policy refers to actual and/or potential clients, customers, suppliers, distributors, business contacts, agents, advisors, and government and public body. The policy also encompasses any of their subsidiaries and/or employees, no matter where they are located (within our outside of the United Kingdom).

Employee Responsibilities

• All employees must ensure that they read, understand, and comply with the information within this policy so that they always act honestly and with integrity to safeguard the group’s resources and reputation.
• All employees and those under our control are equally responsible for the prevention of bribery and fraudulent acts. This involves reporting any potential forms of bribery, corruption, or fraud which anyone may have experienced or seen within our group operations.
• If any employees breach this policy, they will face disciplinary action and could face dismissal as a consequence. The Vista Group has the right to terminate any contractual relationship with an employee if they breach this policy.

Record Keeping

• The Vista Group will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made.

Monitoring and Reviewing

• The Vista Group’s board of directors will be responsible for monitoring the effectiveness of the policy a will review the implementation of it on a regular basis.

Prior Convictions

• The Vista Group can confirm that nobody employed in or by our businesses have been convicted of bribery, fraud, or corruption offences in the past five years.

The Group’s Board of Directors are committed to upholding responsible corporate practices, complying with all laws, regulations, and other requirements to ensure that no form of bribery, corruption or fraudulent activity is present within our business operations. Philip Travis  Group Managing Director