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Anti-Bribery Policy

CCS is committed to conducting its business to the highest legal and ethical standards. CCS will not be party to corruption or bribery in any form. Such acts would damage the business’ reputation and expose the business, its staff and representatives to the risk of fines and possible imprisonment.

CCS takes a zero-tolerance approach to bribery or corruption by its staff and any third party representatives. Individuals involved in corrupt activity may be subject to disciplinary action and may also be fined or sentenced to imprisonment by the authorities.

At CCS, we are fully committed to complying with our obligations under applicable legislation, including the Bribery Act 2010, and ensuring that no bribes or corrupt payments are made, offered, sought or obtained by anyone acting on our behalf.

The Integrated Management System, including Anti-bribery or Corruption provides the framework for setting, reviewing and achieving anti-bribery objectives which are reviewed at regular intervals for continuing suitability.

CCS is committed to satisfying the requirements of ISO 37001:2016 and to achieving continual improvements of the Anti-Bribery Management System.

The business encourages staff and representatives to raise concerns of bribery or corruption in good faith, or on the basis of a reasonable belief which will remain confidential, and without fear of reprisal. If you are ever in doubt about a situation with which you are presented, always seek advice.

In the event that any issue or concern needs to be raised in relation to bribery or the Anti-Bribery Management System, the Leadership Team will assemble an anti-bribery compliance function to investigate the allegation. The assigned person / persons must hold the competence, status, authority and independence to conduct the investigation.

I have prepared this statement as my commitment to anti-bribery or corruption at CCS. This message shall be communicated and understood throughout the company and I expect that all persons carrying out work upon our behalf, share these values.

This policy statement shall be made available to the public, upon request and subject to annual review to ensure its continued suitability.

Signed by

Mario Abajo Menguez
Chief Executive Officer

Clece Care Services Ltd.
Date: November 2019

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