Policies Cookies Policy Our websites www.reactive-technologies.com, www.reactive-technologies.fr and www.reactive-technologies.fi (the “Site”) use cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. By continuing to browse the Site, you are agreeing to our use of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies: • Strictly necessary cookies. These are cookies that are required for the operation of our Site. • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. • Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, and remember your preferences (for example, your choice of language or region). You can find more information about the individual cookies we use and the purposes for which we use them in the table below: Cookie Name Purpose More information Google Analytics _ga Used to distinguish users. For more information in relation to this cookie please see: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage Google Analytics _gid Used to distinguish users. For more information in relation to this cookie please see: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage Google Analytics __gat Used to throttle request rate. For more information in relation to this cookie please see: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Except for essential cookies, all cookies will expire after two years or less. Terms of website use The following terms (together with the documents referred to therein) govern your use of our websites at www.reactive-technologies.com, www.reactive-technologies.fr and www.reactive-technologies.fi (the “Site”). By using the Site you accept these terms Please read these terms of use carefully before you start to use the Site. By using the Site, you indicate that you accept these terms and that you agree to abide by them. Reactive may revise these terms of use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes Reactive has made, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on the Site. Reactive recommend that you print a copy of these terms for future reference. Information about the operator The Site is operated by Reactive Technologies Limited (“Reactive”), a company incorporated in England with registered number 7130127 whose registered office is 9400 Garsington Road, Oxford Business Park, Oxford, Oxon, England, OX4 2HN. To contact us, please write to us at 9400 Garsington Road, Oxford Business Park, Oxford, Oxon, England, OX4 2HN. There are other terms that may apply to you These terms of use refer to the following additional terms, which also apply to your use of the Site: Reactive’s Privacy Policy which sets out the terms on which Reactive processes any personal data it collects from you, or that you provide to Reactive. By using the Site, you consent to such processing and you warrant that all data provided by you is accurate. The Site uses cookies to distinguish you from other users of the Site. This helps Reactive to provide you with a good experience when you browse the Site and also allows Reactive to improve the Site. For detailed information on the cookies Reactive use and the purposes for which it uses them see Reactive’s Cookie policy. Accessing the Site Access to the Site is permitted on a temporary basis, and Reactive reserves the right to withdraw or amend the service Reactive provides on the Site without notice. Reactive will not be liable if for any reason the Site is unavailable at any time or for any period. From time to time, Reactive may restrict access to some parts of the Site or the entire Site to all or some users of the Site. You are responsible for making all arrangements necessary for you to have access to the Site. You are also responsible for ensuring that all persons who access the Site through your internet connection are aware of these terms, and that they comply with them. Intellectual property rights Reactive is the owner or the licensee of all intellectual property rights in the Site and in the material published on it. All such rights are reserved. Any copying of the Site or any part of the Site for commercial purposes may require a licence from Reactive and Reactive reserves its rights to enforce its intellectual property rights in the Site. You may print off one copy, and may download extracts, of any page(s) from the Site for your personal use and you may draw the attention of others within your organisation to content posted on the Site. You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text. Reactive’s status (and that of any identified contributors) as the authors of content on the Site must always be acknowledged. If you print off, copy or download any part of the Site in breach of these terms of use, your right to use the Site will cease immediately and you must, at Reactive’s option, return or destroy any copies of the materials you have made. Do not rely on information on the Site Reactive aims to update the Site regularly, and may change the content at any time. Although Reactive makes reasonable efforts to update the information on the Site, it makes no representations, warranties or guarantees, whether express or implied, that the content on the Site is accurate, complete or up to date and Reactive is under no obligation to update such content. The content on the Site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on the Site. Reactive’s liability Access to and use of the Site is at the user’s own risk and Reactive does not warrant that the use of the Site or any material downloaded from it will not cause damage to any property, or otherwise minimise or eliminate the inherent risks of the internet including but not limited to loss of data, computer virus infection, spyware, malicious software, Trojans and worms. In addition, Reactive accepts no liability in respect of losses or damages arising out of the changes made to the content of the Site by unauthorised third parties. To the extent permitted by law, Reactive hereby expressly excludes: • all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity; and • any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with the Site or in connection with the use, inability to use, or results of the use of the Site, any websites linked to it and any materials posted on it, including: • loss of income or revenue; • loss of business; • loss of profits or contracts; • loss of anticipated savings; • loss of data; • loss of goodwill; and • wasted management or office time, whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above. This does not affect Reactive’s liability for any liability which cannot be excluded or limited under applicable law (including for fraud). Viruses, hacking, prohibited uses and other offences You may use the Site only for lawful purposes. You may not use the Site: • in any way that breaches any applicable local, national or international law or regulation; • in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect; • for the purpose of harming or attempting to harm minors in any way; • to send, knowingly receive, upload, download, use or re-use any material which does not comply with Reactive’s content standards; or • to transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam). You must not misuse the Site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Site, the server on which the Site is stored or any server, computer or database connected to the Site. You must not attack the Site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. Reactive will report any such breach to the relevant law enforcement authorities and Reactive will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the Site will cease immediately. Suspension and termination Reactive will determine, in its absolute discretion, whether there has been a breach of these terms of use through your use of the Site. When a breach of these terms of use has occurred, Reactive may take such action as it deems appropriate, including: • immediate, temporary or permanent withdrawal of your right to use the Site; • immediate, temporary or permanent removal of any posting or material uploaded by you to the Site; • issue of a warning to you; • bring legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach; • take further legal action against you; or • disclose such information to law enforcement authorities as Reactive reasonably feel is necessary. Linking to the Site You may link to the home page of the Site, provided you do so in a way that is fair and legal and does not damage Reactive’s reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on Reactive’s part where none exists. You must not establish a link from any website that is not owned by you. The Site must not be framed on any other site, nor may you create a link to any part of the Site other than the home page. Reactive reserves the right to withdraw linking permission without notice. Links from the Site Where the Site contains links to other sites and resources provided by third parties, these links are provided for your information only. Reactive has no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. Jurisdiction and applicable law The English courts will have exclusive jurisdiction over any claim arising from, or related to, a visit to the Site although Reactive retains the right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country. These terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales. Trade marks Reactive Technologies is a brand name of Reactive. No licence to use any Reactive trade marks or brand names are given in these terms of use. Privacy Policy Reactive Technologies Limited (“Reactive”) are committed to protecting and respecting your privacy. This policy (together with Reactive’s terms of use and any other documents referred to in those terms of use) sets out the basis on which any personal data Reactive collect from you, or that you provide to Reactive, will be processed by Reactive. Please read the following carefully to understand Reactive’s views and practices regarding your personal data and how Reactive will treat it. By visiting any of our websites at www.reactive-technologies.com, www.reactive-technologies.fr and www.reactive-technologies.fi (the “Site”) you are accepting and consenting to the practices described in this policy. For the purpose of the Data Protection Act 1998 (the Act), the data controller is Reactive Technologies Limited of 9400 Garsington Road, Oxford Business Park, Oxford, Oxon, England, OX4 2HN. Information Reactive collect from you Reactive will collect and process the following data about you: • Information you give us. This is information about you that you give to Reactive by filling in forms on the Site or by corresponding with us by phone, e-mail or otherwise. The information you give may include your name, address, e-mail address and phone number. • Information Reactive collect about you. With regard to each of your visits to the Site Reactive will automatically collect the following information: • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform; and • information about your visit, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. The Site uses cookies to distinguish you from other users of the Site. This helps Reactive to provide you with a good experience when you browse the Site and also allows Reactive to improve the Site. For detailed information on the cookies Reactive use and the purposes for which it uses them see Reactive’s Cookie policy. Uses made of the information Reactive use information held about you in the following ways: • Information you give to Reactive. Reactive will use this information: • to carry out its obligations arising from any contracts entered into between you and Reactive and to provide you with the information, products and services that you request from Reactive; • to provide you with information about other products and services it offer that are similar to those that you have already purchased or enquired about; • to notify you about changes to its service; and • to ensure that content from the Site is presented in the most effective manner for you and for your computer. • Information Reactive collect about you. Reactive will use this information: • to administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; • to improve the Site to ensure that content is presented in the most effective manner for you and for your computer; • as part of its efforts to keep the Site safe and secure; and • to make suggestions and recommendations to you and other users of the Site about products or services that may interest you or them. Disclosure of your information You agree that Reactive has the right to share your personal information with: • Any member of its group, which means its subsidiaries, its ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. • Selected third parties including: • business partners, suppliers and sub-contractors for the performance of any contract it enters into with them or you; and • analytics and search engine providers that assist Reactive in the improvement and optimisation of the Site. Reactive will disclose your personal information to third parties: • In the event that Reactive sell or buy any business or assets, in which case it will disclose your personal data to the prospective seller or buyer of such business or assets. • If Reactive Technologies Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. • If Reactive are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply its terms of use. Where Reactive store your personal data The data that we collect from you will not be stored at a destination outside the European Economic Area. All information you provide to Reactive is stored on our or our suppliers’ secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although Reactive will do its best to protect your personal data, it cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once Reactive has received your information, it will use strict procedures and security features to try to prevent unauthorised access. Your rights You have the right to ask Reactive not to process your personal data for marketing purposes. Reactive will usually inform you (before collecting your data) if it intends to use your data for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms Reactive use to collect your data. You can also exercise the right at any time by contacting Reactive at 9400 Garsington Road, Oxford Business Park, Oxford, Oxon, England, OX4 2HN. The Site may, from time to time, contain links to and from the third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and Reactive does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. Access to information The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. You have right to contact us to update, amend or correct your information. You also have the following rights: To request access to, or erasure of, the personal data we hold about you To request us to restrict the processing of the personal data we hold about you. To object to us processing personal data relating to you. Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time. You have the right to obtain certain personal data from us in a format that can be transferred electronically to a third party (also called “data portability”). Please note that some of these rights are not absolute. In some cases, for example, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services, or if we had a legal obligation or right not to comply with the request. However, we will keep you informed as to the actions that we can take, when you make your request. Changes to this privacy policy Any changes Reactive make to this privacy policy in the future will be posted on this page. .Please check back frequently to see any updates or changes to this privacy policy. Contact Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Reactive at 9400 Garsington Road, Oxford Business Park, Oxford, Oxon, England, OX4 2HN. Anti-Bribery & Anti-Corruption Policy 1. What does your policy cover? • This anti-bribery policy exists to set out the responsibilities of Reactive Technologies “Reactive” and those who work for us in regard to observing and upholding our zero-tolerance position on bribery and corruption. • It also exists to act as a source of information and guidance for those working for Reactive. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities. 2. Policy statement 2.1 CO Reactive is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. Reactive has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate. 2.2 Reactive will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regard to our conduct both at home and abroad. 2.3 Reactive recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously. 3. Who is covered by the policy? • This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level. • In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties. • Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption. 4. Definition of bribery 4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision. 4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage. 4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law. 4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a Public Official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager. The term “Public Official” shall include: • Elected or appointed officials • Employees of national, regional or local government (such as inspectors, mayors, and customs agents) • Employees of government-owned or -controlled entities, including corporations or partnerships (such as state-owned oil companies, utilities, media organizations, health care institutions, sovereign wealth funds and the like) • Employees of international public organizations (such as the United Nations, European Union, World Bank and other international development agencies) • Political party officials or candidates for public office • Members of royal families • Any person acting in an official capacity on behalf of a government, government agency, government-owned enterprise or public international organization Note that employees, consultants, and representatives of state, or partially state-owned companies or instrumentality thereof, including national oil and energy companies, are considered Public Officials. 5. What is and what is NOT acceptable 5.1 This section of the policy refers to 5 areas: • Gifts and hospitality. • Facilitation payments. • Political contributions. • Charitable contributions • Hosting of a Public Official. 5.2 Gifts and hospitality Reactive accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements: It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits. It is not made with the suggestion that a return favour is expected. It is in compliance with local law. It is given in the name of the company, not in an individual’s name. It does not include cash or a cash equivalent (g. a voucher or gift certificate). It is appropriate for the circumstances (g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion). It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift. It is given/received openly, not secretly. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them. It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100). It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s CEO, or CFO/CCO. • Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the CEO or CFO/CCO, who will assess the circumstances. • Reactive recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. • As good practice, gifts given and received should always be disclosed to the CEO, CFO/CCO. Gifts from suppliers should always be disclosed. • The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought. 5.7 Facilitation Payments and Kickbacks Reactive does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a Public Official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action. 5.8 Reactive does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage. 5.9 Reactive recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken: Keep any amount to the minimum. Ask for a receipt, detailing the amount and reason for the payment. Create a record concerning the payment. Report this incident to your line manager. 5.10 Political Contributions Reactive will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage. 5.11 Charitable Contributions Reactive accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes. 5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery. 5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager. 5.12 Hosting of Public Officials Neither the Reactive, its directors, managers or employees, when acting for or on behalf of the Reactive, shall offer or authorise anything of value or payments to Public Officials. The Reactive may, however, cover the reasonable and legitimate travel, accommodation and related expenses of Public Officials related to the promotion or demonstration of the Reactive’s products or services or the execution of a contract with public authorities. Note: • Never offer hosting of a Public Official before this is discussed with your line manager and written approval is obtained from the CEO. • Expenses shall always be paid directly by the Company – we do not reimburse expenses. • Prior to approving the hosting, a copy of this Compliance Program must be submitted to the Public Official and his/her relevant employer, and the relevant employer must confirm that the proposed hosting is not in violation of national law or internal policies and procedures. • Any deviation to this rule requires CEO approval 6. Employee Responsibilities 6.1 As an employee of Reactive, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given. 6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy. 6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify either the CEO or CFO/CCO. 6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Reactive has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy. 7. What happens if I need to raise a concern? 7.1 This section of the policy covers 3 areas: How to raise a concern. What to do if you are a victim of bribery or corruption. Protection 7.2 How to raise a concern If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Reactive, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, Finance Director, CEO or CFO/CCO 7.3 Reactive will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially. 7.4 What to do if you are a victim of bribery or corruption You must tell your line manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity. 7.5 Protection If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, [Reactive understands that you may feel worried about potential repercussions. Reactive will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken. 7.6 Reactive will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption. 7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised. 7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or CEO or CFO/CCO immediately. 8. Training and communication 8.1 Reactive will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy. 8.2 Reactive’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter. 8.3 Reactive will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities. 9. Record keeping 9.1 Reactive will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given and understand that gifts and acts of hospitality are subject to managerial review. 9.2 Theresa Kennedy (or her nominated deputy) will maintain and be responsible for updating Reactive’s “Declaration of interest” register upon which all offer of gifts and hospitality, if accepted or not, will be recorded. 10. Monitoring and reviewing 10.1 Reactive’s compliance manager Bob Stonehouse is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness. 10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice. 10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager. 10.4 This policy does not form part of an employee’s contract of employment and Reactive may amend it at any time so to improve its effectiveness at combatting bribery and corruption. About Us Reactive Technologies is a highly innovative energy tech company providing grid operators and renewable asset owners with market-leading and mission-critical technology solutions to accelerate the clean energy transition. Quick Links Media Careers Contact Case Studies Proud Members of Social Media Privacy Policy Health and Safety UK Tax Policy Bribery & Corruption ©2021 Reactive Technologies LTD Contact