Introduction

The action and conduct of DAS officers, Directors and employees (collectively DAS personnel) as well as others acting on DAS behalf are essential to maintaining these standards. To that end, all DAS personnel, including agents, consultants and contractors as well as suppliers involved in DAS international business must read, become familiar with and comply with this Anti-Bribery Policy.

Compliance with Anti-Bribery Laws

It is DAS Policy to comply with all laws, rules and regulations governing anti-bribery and corruption law, in all the countries where we operate. DAS has a zero-tolerance approach to acts of Bribery and corruption, by employees or anyone acting on our behalf. Any breach of this policy will be regarded as a serious matter by the Company, which is likely to result in disciplinary action.
Under UK law (UK Bribery Act 2010), bribery and corruption is punishable for individuals by up to ten years imprisonment. If the company is found to have taken part in the corruption or lacks adequate procedures to prevent Bribery, it could face an unlimited fine and be excluded from tendering for Government contracts and face untold damage to its reputation.
The payment or offer to pay bribes, or provisions of, or offer to provide gifts or anything of value for improper purposes, to obtain or retain business or any other benefit (whether for DAS or any other party) is prohibited. Such payments or gifts are also forbidden under the terms of this policy and may result in immediate dismissal for those involved in their payment or receipt.
DAS is required to keep financial records and to have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

Application of the Policy

This policy applies to individual employees, agents, sponsors, intermediaries, consultants or any other people or bodies associated with DAS or any of its subsidiaries and employees. Bribery is committed when an inducement or reward is provided in order to gain any commercial, contractual, regulatory or personal advantage for DAS or another party.
No bribes of any sort may be paid or accepted from customers, suppliers, politicians, government advisors or representatives, private person or Company. It is not permitted to establish accounts or internal budgets for the purpose of making or facilitating bribes or influencing transactions (slush funds).
DAS recognises that to refuse a gift in certain circumstances and/or countries would cause offence to our trading partners. The test to be applied in all circumstances is whether the gift or entertainment is reasonable and justifiable. What is the intention of the gift? Is the gift being offered for something in return (quid pro quo)? This policy does not prohibit the following practices providing they are customary in a particular market, or are appropriate and properly recorded (please refer to our code of conduct and gifts policy for further information): normal and appropriate hospitality (given or received), and the giving of ceremonial gifts on a festival or at another special time, up to and not exceeding the value of 100 Euros.

Employee Responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees throughout the Group.

Reporting Incidents of Bribery and Corruption

If you become aware that an activity or conduct has taken place which you suspect is a bribe (or corrupt), you have a duty to report this. Any such incidents should be reported to your Supervisor / Line Manager or directly to the Chief Executive Officer.