ANTI-CORRUPTION AND BRIBERY POLICY
Limar Oil Tools (UK) Limited, trading as LiMAR Well Intervention Products is committed to conducting business with the highest ethical standards, integrity, and in full compliance with the law. We take a zero-tolerance approach to bribery, corruption, and any form of unethical behaviour. We are committed to upholding the UK Bribery Act 2010 and applicable laws in all jurisdictions where we operate.
All employees, contractors, suppliers, and third parties working on behalf of LiMAR Well Intervention Products, are expected to comply with this policy and to act responsibly, transparently, and honestly in all business dealings.
To uphold this commitment, LiMAR Well Intervention Products will:
- Prohibit the offering, giving, soliciting or accepting of bribes, facilitation payments, or kickbacks in any form.
- Ensure all employees understand their responsibilities in identifying and avoiding bribery and corruption risks.
- Maintain clear and accurate records of financial transactions and gifts/hospitality in line with legal requirements and internal controls.
- Only allow gifts or hospitality where they are reasonable, proportionate, transparent, and not intended to secure a business advantage.
- Prohibit gifts or hospitality that could improperly influence business decisions, especially during tenders or negotiations.
- Forbid contributions to political parties or charitable donations unless pre-approved, legal, and ethical under local laws.
- Communicate this zero-tolerance stance to all staff, suppliers, contractors, and business partners.
- Communicate to all employees the importance of recognising and reporting bribery or corruption.
- Encourage the reporting of any concerns regarding unethical conduct, with protection from retaliation for those reporting in good faith.
- Investigate any suspected breach of this policy thoroughly and take disciplinary action where necessary.
- Reject the use of "off book" accounts or other measures designed to conceal or misrepresent payments.
- Review and update this policy regularly to ensure its continued effectiveness and relevance.
- Take appropriate action in response to red flags such as unusual payment terms, excessive hospitality, or suspicious third-party arrangements.
- Require all staff to read, understand, and comply with the principles of this policy, and to complete anti-corruption awareness training during induction and periodic refresher sessions.
Each employee and individual working on behalf of the company is responsible for adhering to this policy and reporting any concerns to their line manager or the Finance and Admin Manager.
ANTI-SLAVERY & HUMAN TRAFFICKING POLICY
LiMAR Well Intervention Products is committed to acting ethically and with integrity in all its business operations and relationships. We have a zero-tolerance approach to modern slavery and human trafficking and are fully committed to ensuring that slavery, servitude, forced labour or human trafficking does not occur in any part of our business or supply chain.
We recognise our obligations under the Modern Slavery Act 2015, and we are dedicated to ensuring transparency and fairness in our business practices. This commitment extends to all employees, suppliers, contractors and stakeholders with whom we engage.
To support this commitment, LiMAR Well Intervention Products will:
- Conduct all operations in a manner that actively prevents modern slavery and human trafficking.
- Expect the same high ethical standards from all third parties, contractors and suppliers.
- Include anti-slavery and trafficking clauses in contracts where relevant, ensuring that all partners share our values and responsibilities.
- Maintain and regularly review internal systems and controls to identify and mitigate risks of modern slavery.
- Provide awareness training during induction and refresher sessions where relevant, to ensure employees understand modern slavery risks and responsibilities.
- Encourage all staff and third parties to report any concerns or suspicions of slavery or trafficking through the appropriate internal channels.
- Protect whistleblowers who raise genuine concerns in good faith and ensure they do not suffer any form of retaliation or disadvantage.
- Take prompt action if modern slavery is identified or suspected, including working with partners to remedy situations or terminating relationships where necessary.
- Communicate this policy to all employees and relevant external parties to reinforce our commitment.
- Promote continuous improvement and update this policy regularly in line with evolving legislation and best practice.
Each employee is responsible for upholding the principles of this policy and reporting any suspected breaches. The contents and effectiveness of this policy will be reviewed regularly to ensure it remains appropriate and effective in meeting its aims.