Anti-Bribery and Corruption Policy

Wogen Group (“the Group”) values its reputation for sound ethical dealings with the various organisations with whom it undertakes business.

The Group takes a clear view that it expects, and supports its employees in ensuring, that they act professionally and with integrity in relation to their dealings with business partners, including actual and potential customers, suppliers, intermediaries, referrers of business, contractors, distributors, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.

Employees of the Group should under no circumstances offer or accept:

  • Any financial or monetary payment for commercial return or as a bribe or inducement to secure business;
  • A gift or other form of benefit to a supplier, customer or contractor with the aim of securing or retaining business or gaining some material benefit from undertaking business with the other party.

The Group’s employees are expressly required to indicate their understanding and acceptance of this policy.

      1. Integrity
        The Group and its employees will always be honest and open in all business dealings both inside and outside the organisation.
      2. Compliance with the Law, Regulations and Sanctions
        It is the Group’s policy to be in compliance with all laws and regulations including sanctions applying to its business operations, wherever they may be situated.
      3. Ethics
        We will seek to ensure that all employees conduct themselves in an ethical manner in all dealings on the Group’s behalf. We expect honesty, fairness and courtesy both in dealing with each other and with our external contacts, as well as encouraging the contribution from others and respecting different viewpoints.
      4. Confidentiality
        All employees are expressly forbidden from revealing or communicating to any third party, confidential information that is entrusted or becomes known to them whilst carrying out their duties for the Group.
      5. Conflicts of Interest
        All employees must avoid involvement in outside activities that could (or potentially) conflict with the employee’s loyalty; or might adversely affect the employee’s judgement and objectivity or time spent on Group business; or might reasonably be construed by others as such.  Any employee or other member of staff who is aware of any business dealings conferring, or potentially conferring, personal gain, or involving relatives or associates of members of staff, must supply details of such transactions in writing to the Group Chief Executive Officer.
      6. Business Gifts and Corporate Hospitality
        As a general guideline, business gifts and excessive hospitality should not be accepted by any employee or other member of staff.  The intention of the policy is to ensure that the Company can demonstrate that no undue influence has been applied or could be said to have been applied by any supplier or anyone else dealing with the Company. Accordingly, staff must not accept business gifts or excessive hospitality which might be deemed by others to have influenced a decision. If there are any doubts as to whether acceptance of a gift or hospitality is appropriate, the Group Chief Executive should be consulted.
      7. Expenses
        Expenses are only recoverable if the expenditure is reasonably and necessarily incurred on behalf of the Group and complies with the Group’s expenses policy from time to time.  Receipts should accompany claim forms, and expenses must normally be claimed within three months of being incurred.
      8. Price Fixing
        Employees must not collude with a third party to fix illicit minimum, maximum or range bound prices of any of the metals, minerals or materials in which the Group trades.
      9. Bullying
        Employees must not bully any person. For the purpose of this code of conduct bullying is considered to be intimidating, malicious, insulting or humiliating behaviour which attempts to undermine, hurt or humiliate an individual or group.
      10. Discrimination
        Employees shall at all times act fairly, reasonably and without discrimination. An employee must not discriminate directly or indirectly against any other person on grounds of race, colour, ethnic or national origin, sex, marital status, sexual orientation, disability, age, political persuasion or religion.
      11. Sexual Harassment
        Employees must not engage in sexual harassment of any kind including unwanted conduct of a sexual nature, the display of offensive materials, asking for sexual favours, making decisions on the basis of sexual advances being accepted or rejected.


    2. All organisations face the risk of things going wrong or of unknowingly harbouring malpractice.  The Group believes it has a duty to identify such situations and take the appropriate measures to remedy the situation.  By encouraging a culture of openness within our organisation the Group believes it can help prevent malpractice – prevention is better than cure.  That is the aim of this policy.  By encouraging a culture of openness, the Group wants to encourage you to raise issues which concern you.  You may be worried that by reporting such issues you will be opening yourself up to victimisation, detriment or risking your job security; that is quite understandable.  The Group will do everything in its power to protect you and ensure that you are not prejudiced in your position and the workplace.  Provided you are acting in good faith, it does not matter if you are mistaken.  There is no question of you having to prove anything.  If there is anything which you think the Group should be aware of please use the procedure outlined in this document.  In short, please, do not hesitate to “blow the whistle” on malpractice.
    3. Malpractice occurs when an area of the Group, team of people, or an individual is undertaking activity which fits any of the following categories:
      • Against the law or operating regulations
      • Fails, or has failed, to meet legal obligations
      • Where a miscarriage of justice is occurring or has occurred
      • Where the health and safety of an individual has been or is likely to be endangered
      • Against Group policy (e.g. acceptance of bribes)
      • Information evidencing the above is being, or has been, concealed


      This is not an exhaustive list, therefore if there is anything else that you think the Group should be aware of please use the procedure outlined in this policy.  By knowing about malpractice at an early stage we can take the necessary steps to safeguard the interests of everyone.  This procedure is not a substitute for the normal Grievance Procedure or other relevant policies and is not a channel for raising matters in relation to your terms and conditions of employment.

      1. Our Commitment
        The Company is committed to this policy. If you use this policy to raise a concern the Group gives you its assurance that you will not suffer any form of retribution, victimisation or
        We will treat your concern seriously and act according to this policy. You will not be asked to prove anything. If you ask for a matter to be treated in confidence the Group will respect your request and only make disclosures with your consent. You will be given feedback on any investigation and the Group will be sensitive to any concerns you may have as a result of any steps taken under this procedure.
      2. How to raise your concern
        Anyone who is concerned about any form of malpractice should raise the issue with the Chief Executive Officer or if they feel unable to tell the CEO should raise the issue with a Non-Executive Director of Sanctuary Partners Limited, the holding Company for the Group.
      3. How the Group will respond
        • After you have raised your concern the Group will decide how to respond in a responsible and appropriate manner under this policy. Usually this will involve making internal enquiries first, but it may be necessary to carry out an investigation at a later stage which may be formal or informal depending on the nature of the concern raised and may involve the Group’s auditors or professional advisers.
        • As far as possible, the Group will keep you informed of the decisions taken and the outcome of any enquiries and investigations carried out. However, the Group will not be able to inform you of any matters which would infringe the duty of confidentiality owed to others.