Anti-Bribery Policy

1. Introduction

It is the policy of Bandai UK Ltd (BUK) to conduct business in a fair, honest and transparent way and not to use corrupt practices or acts of bribery to obtain an unfair business advantage. BUK is committed to ensuring adherence to the highest ethical and legal standards and to bringing integrity to every aspect of its business activities, in line with the BANDAI NAMCO Group's Declaration of Compliance.

This policy has been adopted by the BUK Board and is to be communicated to everyone involved in our business to ensure their commitment to it. The Board attaches the utmost importance to this policy and will apply a "zero tolerance" approach to acts of bribery and corruption by any of our employees or business partners working on our behalf which contravene the Bribery Act 2010. BUK will treat any breach of this policy as a serious matter which is likely to result in disciplinary and/or legal action.

2. Policy

BUK prohibits the offering, giving, demanding or receiving of any bribe whether in the form of cash or any other inducement:

  1. to or from any person or company, whether a public official or body, or a private person or company wherever situated
  2. by any individual employee, agent or other person or company acting on behalf of BUK
  3. in order to gain any commercial, contractual or regulatory advantage for BUK in a way which is unethical
  4. or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

3. Gifts & Corporate Hospitality

Gifts and corporate hospitality include the offering or acceptance of:-

  1. gifts and tokens of appreciation and gratitude
  2. invitations to events, functions or other social gatherings

As long as they fall within reasonable bounds in terms of value and occurrence, the following activities are allowable:

  1. gifts may be offered at festive occasions, eg Christmas, as part of the overall account management process provided that they are appropriate to the scale of the business relationship between the recipient and BUK and are approved beforehand by the MD or FD.
  2. similar festive gifts may be accepted by BUK staff provided that they are appropriate to the scale of the business relationship between the donor and BUK. The recipient is required to keep a record of such gifts to be available for inspection by his or her immediate line superior, if necessary.
  3. the provision of any form of corporate hospitality as outlined above must be transparent and always be approved beforehand by the MD or FD.
  4. The acceptance of any similar form of corporate hospitality by BUK staff must be notified either to the MD or the FD beforehand for their approval.

For the avoidance of doubt:

  1. the provision or acceptance of gifts or corporate hospitality during the tendering or procurement process is prohibited.
  2. no facilitation payments to foreign officials for securing or accelerating routine processes or procedures are allowed, regardless of amount.
  3. expenses incurred on normal business travel, accommodation, subsistence or normally allowable business entertaining are exempt provided that they are in line with the company's Expenses Policy at Section 19 of the Employee Handbook and are properly approved.

 4. Employee Responsibility

The prevention, detection and reporting of bribery is the responsibility of all BUK employees. If and when any instance of bribery is identified, the incident or suspected incident of bribery must be reported immediately in accordance with the company’s “Whistle Blowing” policy, which provides details of who to contact with any concerns or doubts as to whether a potential act constitutes bribery.

Managers must ensure that all employees are aware of this policy and of their responsibilities to act accordingly.