Anti-Bribery Statement

Anti-Bribery and Corruption Statement

Approved by the Directors on 9th July 2018

Introduction

In line with our core values, Intelligent Energy insists on honesty and integrity in all aspects of our business.

Intelligent Energy is governed by a range of anti-bribery and anti-corruption legislation that applies to the Intelligent Energy business worldwide including the Bribery Act 2010 (UK), the Foreign Corrupt Practices Act of 1977 (US) and the Indian Prevention of Corruption Act. This legislation can result in both Intelligent Energy and individuals being guilty of civil and criminal offences.

We all have a responsibility to be alert to the risks, however small, in both our business and in our wider supply chain. Our employees are expected to report concerns and management are expected to act upon them. We do not support or deal with any person or business knowingly involved in bribery or corrupt practices. Our internal policies make it clear that employees must not offer or receive any bribe or facilitation payment or enter into corrupt practices of any kind.

 

Our Business

We deliver clean energy solutions for our target markets, through the development and manufacture of modular fuel cell stacks and systems. Our principal facility and headquarters is located in Loughborough, UK. As at the date of this statement we also operate in Japan, India and the US.

 

Our supply chains

Our supply chains include the sourcing of materials principally in relation to the manufacture and testing of our fuel cell products. Over 95% of suppliers that we have used in the last 12 months are based within the UK, or other areas of the world that we class as low risk for the purposes of bribery and corruption. For suppliers in high risk territories, we have more stringent checks carried out by our Procurement team, where deemed necessary.

 

Our policy on bribery and corruption

Intelligent Energy is committed to conducting all aspects of its business in an ethical and transparent manner.

We acknowledge our duties and responsibilities under applicable legislation, such as Bribery Act 2010 (UK), the Foreign Corrupt Practices Act of 1977 (US) and the Indian Prevention of corruption Act (the “Acts”).

 

We are committed to acting with honesty, integrity and transparency in all our business dealings worldwide, and do not tolerate any form of bribery or corruption in our organisation or within the supply chains. We expect the same high standards from all our suppliers, contractors and business partners.

 

Supplier adherence to our values

Our Anti-Bribery and Corruption Policy and Supplier Code of Conduct is regularly reviewed to reflect our commitment to compliance with the Acts.

 

All new suppliers, contractors and business partners that we choose to work with (whether classed as high risk or not), are required to sign up to our Supplier Code of Conduct; this document confirms the standards we expect our suppliers to up-hold in relation to labour/human rights; health & safety; environment; ethics; management systems; anti-bribery and corruption; and modern slavery and human trafficking.

 

Responsibilities for policy compliance

The Directors are ultimately responsible for the overall compliance of our legal and ethical obligations under the Acts.

 

All employees are responsible for their own compliance and must ensure that they adhere to our Policies including our Anti-Bribery and Corruption Policy, and Gifts and Hospitality Policy, which governs the acceptance and/or provision of gifts and hospitality by those working for Intelligent Energy as a result of work related activities. In order to protect our reputation, it is vital that all employees understand their obligations under the Policies and comply with it at all times.

 

Under the leadership of the Head of Product Delivery, the Procurement team is responsible for ensuring that our policies and procedures are adhered to, with regard to the day-to-day vetting of new suppliers and monitoring our supply chain to ensure compliance with our duties.

 

In addition, compliance with the Acts is the responsibility of all employees, persons or organisations working for or on behalf of the Company.

 

Training

To ensure a high level of understanding of the risks of bribery and corruption in both our supply chain and own business, we offer additional training to relevant employees where required.

 

Reporting of suspected policy breaches

All employees are encouraged to report any concerns they may have in relation to bribery and corruption. We also operate a Whistleblowing policy which allows employees to report such matters. Incidents or concerns raised via this route can be reported directly to the Company Secretary.

 

Alistair Ball

Interim Chief Executive Officer

Intelligent Energy Limited