Policy Framework

Every Reliable business is required to have an effective compliance program that prohibits unethical conduct, which includes but is not limited to, the following components:

		Communication of a code of conduct to employees.
		Reporting and investigation of allegations of fraud, bribery and other corrupt practices.
		Appropriate disciplinary procedures for employees who are found to have engaged in such practices.
		Monitoring of the effectiveness of such controls.

Consequently, Reliable and each of its businesses must take the appropriate steps to ensure that it and all its employees and those acting on its behalf:

		Meet all legal and regulatory requirements governing the lawful and ethical conduct of business.
		Ensure all breaches or suspected breaches of this policy are fully investigated and, if appropriate, invoke disciplinary measures and take prompt action to remedy the breach and prevent any repetition.
		Make all employees aware of their personal responsibilities and adhere strictly and at all times to this policy.
		Provide information to all employees and further guidance if they have any question or uncertainty regarding these requirements.
		Provide information to all employees on the procedures available to them to report any breach or suspected breach of this policy, in accordance with the Group's policy on The Requirement for Written Codes of Ethics for employees (incorporating) Whistleblower Protection.
		Include in agreements with third parties, in connection with international ventures or projects, appropriate clauses to ensure that persons who are acting on Reliable 's behalf do not engage in any illegal, improper or questionable conduct, particularly if there are factors that might increase the risk of breach of this policy, such as accepted custom and practice within the country of operation.
		Prohibit employees or persons and entities acting on behalf of Reliable to receive, offer, promise, improperly influence payment, authorise payments or contract award, directly or indirectly, in return for anything of value (for example a bribe or kickback). Further guidance should be sought from the policy documents detailed in section 4.
		Prohibit payments including "facilitating" or "expediting" payments to others in order to secure prompt or proper performance of routine duties.
		Prohibit the use of subcontracts, purchase orders or consulting agreements either as a means of channelling payments, or otherwise rewarding such persons or their relatives or business associates.
		Ensure transactions are properly and accurately recorded.

The relevant laws extend to activities undertaken by others acting on Reliable's behalf. Their actions can subject Reliable to liability and therefore care should be taken to ensure that contractors, agents and others who are acting on behalf of Reliable do not engage in any illegal or improper conduct.

Every Reliable business is expected to take firm disciplinary action in cases of proven fraud, bribery or other corrupt practices. This will very likely be immediate termination. Furthermore, all significant cases of such practices shall be reported to the public authorities unless the Group Company Secretary and General Counsel approves otherwise.

Resources are available to assist Reliable businesses to implement this policy by the provision of advice on its terms and specific issues that arise. Please contact the Policy Lead for further information.