Bribery Act 2010 Statement

Introduction

Hemiko is a fast-growing innovative business looking to invest in and deliver over £1bn of heat network projects in the coming years. We fund, design, build, operate and maintain low carbon district energy networks and building energy systems. We work with local authorities, developers, house builders and property owners to decarbonise communities, towns and cities.

Our vision is to be a leader in town and city scale decarbonisation. We operate across the United Kingdom and pride ourselves on our reputation for acting fairly and ethically wherever we do business. Our reputation is built on our company values, those of our employees and our collective commitment to acting with integrity throughout the organisation.

Statement

Hemiko condemns corruption in all its forms and we will not tolerate it in our business or in those with whom we do business. From the confines of our working environments, it is sometimes difficult to grasp the scale of the damage that bribery does to societies. It is not a victimless crime; far from it:

"Corruption ... undermines democracy and the rule of law, leads to violations of human rights, distorts markets, erodes the quality of life and allows organised crime, terrorism and other threats to human security to flourish. This evil phenomenon is found in all countries - big and small, rich and poor...corruption hurts the poor disproportionately by diverting funds intended for development, undermining a government's ability to provide basic services, feeding inequality and injustice and discouraging foreign aid and investment. Corruption is a key element in economic under-performance and a major obstacle to poverty alleviation and development." (Kofi Annan, former UN Secretary General)

Our Anti-Bribery and Corruption Policy sets out in detail how the business should behave and what should be done if confronted with corruption. We expect staff to embrace the Anti-Bribery and Corruption Policy and its values and use them in all aspects of day-to-day work.

The Anti-Bribery and Corruption Policy is for the benefit of our staff as much as for the business. If convicted of a bribery offence, individuals could face up to ten years in prison. The potential harm done by bribery is long term and hugely outweighs any potential short-term gain. If convicted of a bribery offence the business could face significant fines and suffer lasting reputational damage. It could also be excluded from future tender lists, and therefore stop the business from achieving its growth aspirations. Bribery is just not worth the risk.

Staff with any doubts about anything at all, are encouraged to refer to the Anti-Bribery and Corruption Policy, Whistleblowing Procedure (including for information regarding the Independent Whistleblowing Charity) or are able to speak to senior management or the HR team in complete confidence. If staff are not comfortable reporting this internally it is possible to speak to the police. We are committed to eradicating corruption and we will stand by staff acting ethically.

We are committed to reviewing our anti-corruption procedures periodically to ensure they are sufficiently robust to prevent corruption in any part of our business or supply chain.

Staff are reminded to take the RIGHT approach to eradicate corruption together:

• Responsibility. Everyone is responsible for their actions. Breaking the law means facing the consequences - which could mean a fine, imprisonment, or both.
• Integrity. Integrity should never be compromised. If something is wrong, it should ALWAYS be reported. If in doubt the Anti-Corruption and Bribery Policy should be consulted. No-one should ever be forced into doing something they know, or suspect is wrong.
• Genuineness. Always pay genuine prices for genuine goods and services; ever pay over the odds. Agents who ask for especially large fees or commissions may do so in order to pay bribes and where this happens those that have accepted higher prices will be held responsible. Excessive payments are obvious and will always be uncovered.
• Honesty. Staff are encouraged to act honestly and in good faith at all times and in all aspects of their work.
• Transparency. Staff are encouraged to maintain accurate records (including all invoices and receipts) for everything they do, especially in relation to the payments. Full and accurate records demonstrate complete transparency and that there is nothing to hide.

Don't bribe. Do the RIGHT thing.

Toby Heysham
Chief Executive Officer