It is the policy of Ithaca Energy Inc and Ithaca Energy (UK) Limited (together “Ithaca”) to conduct business in an honest and ethical manner. Ithaca do not tolerate, permit, or engage in bribery, corruption, and are firmly against the making of improper payments of any kind in our business dealings, anywhere in the world, in either the public or the private sector. Ithaca are committed to acting professionally, fairly and with integrity in all our business dealings and relationships, wherever we operate, and implementing and enforcing effective systems to counter bribery and corruption.
Ithaca aims to limit exposure to bribery through the enforcement of the Ithaca anti-bribery and corruption policy (the “Policy”) which requires adherence to relevant anti-bribery and corruption legislation (including without limitation the Bribery Act 2010) and encourages every employee and associated third party to practice and promote ethical and honest business practices at all times.
The Policy specifically prohibits the offering, giving, solicitation or the acceptance of any bribe, (whether in cash or in the form of any 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 Ithaca's behalf in order to gain any commercial, contractual or regulatory advantage for Ithaca in a way which is unethical or in order to gain any personal advantage, pecuniary or otherwise.
Ithaca is in the process of communicating the Policy to everyone involved in Ithaca’s business to ensure their commitment to it. Ithaca attach the utmost importance to the Policy and will apply and enforce a strict “zero tolerance” approach to acts of bribery and corruption by any of our employees, contractors or business partners working on our behalf. Any breach of this policy will be regarded as a serious matter by Ithaca and will result in disciplinary action for employees, including where appropriate summary dismissal and any third parties associated with Ithaca who are found to be exposing Ithaca to bribery and corruption risk will be investigated and appropriate action will be taken.
Any concerns relating to a breach of this policy should be reported to the Ithaca Legal Department by contacting Anne-Marie Fraser or Vicky Corley.