Anti Bribery & Corruption Policy

Introduction

Argonaut Capital Partners LLP (‘Argonaut’) is committed to ensuring adherence to the highest legal and ethical standards and recognises the damage that financial crime can cause to individuals, the economy and society as a whole.

Argonaut fully supports the FCA in its objective to reduce the scope for financial crime and is committed to acting fairly, professionally and with integrity and will not tolerate any form of bribery or corruption.

Bribery is a criminal offence and corrupt acts expose Argonaut and its employees to the risk of prosecution, fines and imprisonment, as well as endangering Argonaut’s reputation. Being involved in any form of bribery or corruption is very serious and will have serious implications for any employee, third party, sub-contractor or Adviser involved with the Firm.

Scope

This policy applies to Argonaut, its employees and agents. This policy has been adopted by Argonaut’s management team and is communicated to everyone involved in the business to ensure their commitment to it. Compliance with Argonaut’s Anti-Bribery and Corruption Policy is regarded as part of an employee’s contract of employment at the firm.

The Policy

Acts of bribery or corruption are designed to influence the individual in the performance of their duty and incline them to act dishonestly.

Bribery: Is the offer, promise, giving, demanding or acceptance of an advantage as an inducement for an action which is illegal, unethical or breach of trust.
Corruption: Is the misuse of a public office or power for private gain; or misuse of private power in relation to business outside the realm of government.

Argonaut has a zero tolerance to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships, implementing and enforcing effective systems. The zero tolerance to bribery extends to all of Argonaut business dealings.

Therefore, Argonaut, its employees, officers and agents must not solicit, offer or accept any gift or inducement which may influence their independence or business judgement, or which could create a conflict with any duty owed to the company or its customers and other stakeholders.

Hence, Argonaut prohibits the offering, the promising, the giving, the solicitation and the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company by any individual, employee, agent or other person or body acting on Argonaut’s behalf in order to gain:

Any commercial, contractual or regulatory advance for Argonaut in any way which is illegal and does not comply with The Bribery Act 2010 or
Any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

Third Parties

Argonaut communicates our anti-bribery policy and requirements of third parties where appropriate, by the imposition of contractual terms. Argonaut requires business counterparties to implement effective policies to counter bribery and corruption in their own dealings and those associated with Argonaut, especially where there is no contractual business relationship.

(*Note: Third parties, here, include any individual or organisation doing business with Argonaut, or whom an employee comes into contact during the course of their work for Argonaut and therefore includes clients, advisers, suppliers, distributors, business contacts, correspondents, agents, service providers, brokers and government and public bodies).

Further Clarification

This policy is not meant to prohibit corporate gifts and hospitality which are considered to be incidental to the ordinary business of Argonaut. Examples of gifts and inducements which should not be offered or accepted include cash, gifts readily convertible into cash or any other object or hospitality of significant value.

All gifts and hospitality over £100 should be reported to Compliance and added to the ‘Gift Log’. Normal business meals such as lunch, dinner, coffee meetings, etc. are excluded. Argonaut employees should always refer to Compliance if in doubt as to what they need to disclose. All gifts/ hospitality in excess of £250 in value have to be pre-agreed and signed off by a member of the management team and compliance before being accepted.

Employee Responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees throughout Argonaut. Where knowledge or suspicion or reasonable grounds of suspicion exist, personnel should make a Suspicious Activity Report and/or refer the matter to the Compliance Officer.