Quality Statement

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1. Introduction

This policy aims to establish the Fourfront Group, comprising Area, Sketch Studios and 360

Workplace, approach to issues of bribery and to set out the behaviour we expect of everyone either employed or engaged by us when conducting business on our behalf.

The Group expects its employees to demonstrate honesty, integrity and fairness in all aspects of their business dealings and exercise appropriate standards of professionalism and ethical conduct in all their activities. The Group expects the same approach to doing business from its business partners and suppliers.

The Group will not tolerate bribery or corruption in any form and has a ‘zero tolerance’ approach to any breach of this Policy. The Group and all its employees must follow this Policy and must not seek, accept or give a bribe, facilitation payment, or other improper or illegal payment.

The Group seeks to adhere to the requirements of ISO 37001:2016, Anti-Bribery Management Systems.

2. Definition

A Definition of Bribery: The receiving I offering I giving / providing / requesting I accepting of a financial or other advantage, in order, to seek to induce a person or to induce a person to give improper assistance in breach of their duty, or to otherwise influence someone with the underlying purpose of obtaining/retaining business, or an advantage in the course of business.

3. Policy Details:

The Group will take appropriate steps to ensure that:

3.1) We do not, directly or indirectly, offer, promise, give, accept or demand a bribe (including excessive gifts and hospitality) in order to obtain or retain business, or gain any other improper advantage.

3.2) We do not offer, nor accept demands, to make illicit or illegal payments to intermediary agents, public officials or the employees of clients, business partners or anybody else that we do business with.

3.3) We will engage and remunerate intermediary agents and other third parties only for mlegitimate services and adopt appropriate transparency in our approach (as further detailed in this Policy, our Supplier Purchase Order Terms and our Client Terms and Conditions).

3.4) We promote employee awareness of, and compliance with, our Group policy against bribery and corruption through appropriate dissemination of our own procedures (including disciplinary procedures), as well as training programmes carried out both on induction and subsequently.

3.5) We adopt management control systems that discourage bribery and corruption, and adopt financial and tax accounting as well as auditing practices that prevent the establishment or concealment of illegal payments.

3.6) We raise awareness of the need to combat bribery and corruption with our business partners by publication of this Policy and (where appropriate) relevant contractual provisions and support initiatives designed to reduce the risk of bribery and corruption.

4. Responsibility

The policy is supported by all Directors within the Group, and shall be reviewed annually. In particular:-

4.1) The provisions of the policy will be rigorously enforced and any infringements could result in disciplinary action being taken under formal procedures including in the most serious cases dismissal from the Group, a police referral for criminal prosecution and a claim for recovery of loss or damage.

4.2) Directors are responsible for ensuring their staff are familiar with the contents of this Policy. An ‘open door’ policy is encouraged so that, if necessary, any queries and concerns can be brought to the attention of any Group Directors.

4.3) All staff should promptly report to a Group Director any illegal or un-ethical behaviour of which they become aware.

5. Gifts, Entertainment and Hospitality

We recognise that reasonable hospitality to meet, network and improve relationships with third parties is a normal part of business and is an acceptable company practice. Therefore this policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties.

The giving or receipt of gifts is not prohibited, if the following requirements are met:

5.1) it complies with local law;

5.2) it does not include cash or a cash equivalent (such as gift certificates or vouchers);

5.3) taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time; and

5.4) it is given openly, not secretly.

5.5) must be approved first and added to the gifts and hospitality register

6. Referral Fees

We recognise that a Group company may pay referral fees to a Third Party as part of its ordinary course of business. Our standard client terms and conditions, and our terms and conditions of purchase, confirm that such payments may be made. This Policy does not prohibit such payments, but such payments may only be made if the conditions below are met. If a payment is made which is prohibited by the below conditions, this will be in breach of this policy and the employee responsible may be subject to disciplinary conditions.

The following issues (not an exhaustive list) must be considered:

• the payment must (subject to the below) be paid to a Third Party Registered Company (not an Employee of the Third Party Company);

• the payment may only be made directly to an employee of the Third Party Company with the express written permission of said Company;

• the payment must relate to a particular service provided by the Third Party

• payments in kind (for example a car, vouchers or a holiday) are prohibited; and

• authority of a director of the relevant Group company (or where appropriate a person nominated by the directors of a Group company) must be obtained prior to any payment being made.

7. Red Flags

The following are examples of possible ‘red flags’ that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.

If you encounter any of these (or any other) red flags while working for us, you must report them promptly to your Managing Director:

• a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us;

• a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or refuses to provide an invoice or receipt for a payment made;

• a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;

• a third party requests an unexpected additional fee or commission to “facilitate” a service;

• a third party demands (or offers) lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;

• a third party requests that a payment is made to “overlook” potential legal violations;

• you receive an invoice from a third party that appears to be non-standard or customised;

• a third party insists on the use of side letters or refuses to put terms agreed in writing;

• you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;

• a third party requests or requires the use of a spouse, friend, relative, agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;

• you are offered an unusually generous gift or offered lavish hospitality by a third party.

8. Further Information

If you have any questions regarding the Anti-Bribery Policy, please contact the People Team.

Fourfront Group Competition Policy

Fourfront Group is committed to ensuring fair competition to give the best outcomes for its customers. We maintain a comprehensive Competition Policy, a copy of which can be read here, to ensure we are compliant with competition law and its guiding principles of fairness and transparency.

Fourfront Group Anti-Slavery Statement

The Modern Slavery and Human Trafficking Statement has been published by Fourfront Group in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Fourfront Group to prevent modern slavery and human trafficking in our business and supply chains.

For more information, view our Modern Slavery Act Statement here.

Statement by the directors in performance of their statutory duties in accordance with s172(1) Companies Act 2006

S172(1a) When making strategic and financial decisions the directors consider various possible outcomes and consult with internal and external stakeholders to help the Group achieve the best possible outcome. In making these decisions and consulting with various groups, the board members act in good faith on behalf of the Group to achieve sustainable long-term growth.

S172(1b) The Group understands the importance its employees play in achieving its strategic goals. In this regard, the Group makes it a priority to attract, retain and motivate employees. The Group actively promotes its values linked to the “Fourfront Way” and this creates a highly focused culture of staff engagement. The Group also carries out regular staff engagement surveys and actively responds and creates solutions to address any issues discovered.

S172(1c) The Group works with suppliers, customers and the community to foster improved relationships and accountability. We work in an environment of continuous quality and relationship improvement to exceed client expectations by working closely with our entire supply chain. The Group regularly meets with its preferred and approved supply chain group to promote good communications and build trusted relationships. We also partner with various community organizations to give back to the communities that we serve. The Group actively support our employees’ participation in activities to support our chosen charity – Shooting Star Chase and has helped to raise significant funds for the charity over the years. The Group also allows all employees 3 paid days per year to take part in charity work.

S172(1d) The Group works diligently to ensure that we are complying with all local laws and regulations. We engage regularly with professional advisors to ensure that the Group is fully compliant and that it can proactively be prepared for any changing regulations as they occur. We have a well-documented and managed health and safety policy and process and we are ISO 45001 certified (this is the standard for Health and Safety Management Systems) . We have specially identified individuals at all relevant locations who address environmental and safety concerns. With an eye on continuous improvement, we work to reduce waste and thereby reduce pollution from the environment.

S172(1e) The Group monitors government regulations to ensure that we are complying with all necessary laws. Directors of the organisation also must comply with ethical standards to ensure that the Group is maintaining a high standard of business conduct. The Group has a well-documented compliance culture and has a leading industry expert on its board who serves as a non-executive director to ensure that compliance is always at front of mind. The Group is also ISO 37001 anti-bribery and corruption accredited.

S172(1f) The Group considers all stakeholders when making significant strategic and financial decisions. Although considerations are made between the different groups, there is not a requirement to balance the interests of all members in this process, meaning that, at times, certain stakeholder interests may not be fully aligned however all decisions are made to benefit the interests and success of the business as a whole.

Engagement with Suppliers, Customers and Others in a business relationship

The directors work regularly with external parties to ensure smooth operation of the supply chain and to exceed client expectations. The Group works with a trusted panel of preferred and approved sub-contractors and we regularly meet with this group to ensure good communication and excellent delivery standards. Through discussion with employees and directly with external parties’ directors regularly and proactively discuss potential delays, quality concerns and commercial issues with customers and vendors.