Anti-Bribery Policy

Global Telecom Networks operates a zero-tolerance policy with regard to bribery and corruption and all employees of the Company are bound by this policy.

Employees or Global Telecom Networks representatives, whether directly or indirectly, must not offer, promise or give cash or anything of value (including a financial or other advantage) to another individual in the public or private sector to influence that person to act improperly, to reward that improper performance or to obtain or retain business or any other advantage in the conduct of business.

Gifts and hospitality

With regard to gifts, hospitality and expenses the following requirements are mandatory:

• The Company forbids any employee to solicit any gift or hospitality above the value of £10.00 in the course of his/her employment.
• The Company forbids any employee from offering or receiving any gifts (outside of point 1 above), or hospitality from any person or organisation that has had, has or may have any influence over the business of Global Telecom Networks and associated companies, unless it has been agreed in writing by the Director.
• Compliance with this policy is a condition of each employee’s contract of employment.

Every employee has a responsibility to speak out if they suspect corruption or are aware of any gift or hospitality given or received which may be in breach of this policy. Any concern in respect of such breach by: Another member of staff, any supplier or 3rd party, must report it to the Managing Director as soon as possible.

All allegations of any breach of this policy will be investigated and may result in disciplinary action being taken.