ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

Anti-Bribery and Anti-Corruption Policy

Get Cracking Anti-Bribery and Anti-Corruption Policy

Get Cracking Limited is committed to conducting all business lawfully, ethically and with integrity. We have a zero-tolerance approach to bribery and corruption in any form.

This Anti-Bribery and Anti-Corruption Policy sets out the principles and procedures followed by Get Cracking to help prevent bribery, corruption and other improper business practices.

The policy applies to all employees, managers and directors of Get Cracking Limited, as well as agents, contractors, service providers and other third parties acting on our behalf.

We expect everyone representing Get Cracking to understand these requirements and conduct business honestly, transparently and in accordance with applicable laws.

Our approach reflects applicable Irish legislation, including the Criminal Justice (Corruption Offences) Act 2018, which provides the principal legislative framework for corruption offences in Ireland.

Definition of Bribery

Bribery involves offering, promising, giving, requesting, accepting or receiving an advantage with the intention of influencing a person’s actions or decisions improperly.

A bribe does not necessarily involve a direct cash payment. Depending on the circumstances, improper benefits could include gifts, favours, discounts, waived fees, hospitality, travel, tickets, donations, sponsorship, commissions or other benefits.

The important consideration is whether something of value is being offered, requested or accepted with the intention of improperly influencing a decision or action.

Definition of Corruption

Corruption generally involves the abuse of entrusted power or position for improper personal or business advantage.

It may include giving or accepting bribes, requesting improper payments, using influence dishonestly or engaging in fraudulent or unethical conduct.

Get Cracking prohibits bribery and corruption in all forms.

Any employee found to have breached this Anti-Bribery and Anti-Corruption Policy may be subject to disciplinary action, up to and including dismissal where appropriate.

Service Providers, Agents and Business Partners

Get Cracking works with service providers, removal partners, transport providers, agents and other third parties in Ireland and internationally.

We expect third parties acting on our behalf to conduct business ethically and not to engage in bribery, corruption or other improper practices.

Appropriate due diligence should be carried out before appointing a new service provider or business partner, particularly where the nature of the service, location or transaction creates an increased compliance risk.

Risk Assessment When Selecting Service Providers

When assessing a potential service provider or business partner, Get Cracking may consider:

Reputation – Does the company have suitable references and a positive business reputation?

Experience – How long has the organisation been established, and does it have the necessary experience and capability?

Compliance – Does the organisation have appropriate anti-bribery, anti-corruption or ethical business procedures?

Location – Does the country or region in which the organisation operates present an increased corruption risk?

Research – Have appropriate checks been carried out using company websites, business registers, professional directories and other reliable sources?

Payments and commissions – Are proposed payments, fees and commissions reasonable, transparent and consistent with normal market practice?

Documentation – Can the organisation provide appropriate company and legal documentation where required?

International corruption-risk information may also be considered using reputable sources such as Transparency International’s Corruption Perceptions Index.

Our Commitment to Customers and Business Partners

Customers and business partners can expect Get Cracking to conduct business with integrity.

We will:

Never engage in bribery, directly or through a third party.
Never offer, make or authorise an improper payment.
Never attempt to induce an individual or public official to act illegally or improperly.
Never offer or accept money, kickbacks, inappropriate commissions or other benefits in return for securing business or influencing the award of a contract.
Never offer inappropriate gifts or hospitality to public officials or other individuals in expectation of receiving a business advantage.
Never accept a gift or benefit where a return favour is expected or implied.
Never make improper facilitation payments to obtain services or advantages.
Never knowingly disregard indications of bribery, corruption or improper payments.
Never encourage or assist another person to breach applicable anti-corruption legislation.

Compliance With This Policy

Everyone working for or representing Get Cracking has a responsibility to act with integrity and comply with this policy.

Relevant employees receive appropriate guidance and training, and the policy is made available to employees through Get Cracking’s internal systems and website.

Where appropriate, new service providers and business partners may also be provided with a copy of our Anti-Bribery and Anti-Corruption Policy so that our expectations are clear from the beginning of the business relationship.

Any employee who becomes aware of suspected bribery, corruption or another potential breach of this policy should raise the matter with management promptly.

Further information regarding the reporting and investigation of corruption offences in Ireland is available from An Garda Síochána – Anti-Bribery and Corruption.

If you have questions about this policy or concerns regarding an arrangement with a third party, please contact Get Cracking management for guidance.

Anti-Trust Charter

Please also review our Anti-Trust Charter.

Don Langan
CEO
Get Cracking Limited