Anti-Bribery Policy

HAIBUN PARTNERS LLP ANTI-BRIBERY POLICY

Haibun Partners LLP (the “Company”) values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs and to ensuring that the highest standards of honesty and integrity are maintained.

We operate a zero tolerance approach to the making or receiving of bribes or corrupt payments, in any form. This type of conduct is absolutely prohibited whether committed by employees or anyone else acting on the Company’s behalf.

We are fully committed to complying with our obligations under applicable legislation, including the Bribery Act 2010 (the “Act”), and ensuring that no bribes or corrupt payments are made, offered, sought or obtained by anyone acting on our behalf, to anyone, anywhere in the world. A bribe may include any payment, benefit or gift offered or given with the purpose of influencing a decision or outcome. The bribe may not always be of a large value.

Our policy is mandatory for all the Company’s employees, consultants, subcontractors and suppliers. Any failure to comply with this Policy will be treated seriously. We will consider taking disciplinary action against any employee who fails to comply with the anti-bribery policy up to and including dismissal. Failure to comply with the policy may lead to criminal prosecution under the Act. An offence under the Act can result in a fine and/or up to a maximum of 10 years imprisonment.

The prevention, detection and reporting of bribery is the responsibility of all those engaged with the Company.

Any act of bribery, in whatever form is unacceptable.

Haibun Partners LLP prohibits:

  • the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company by any individual employee, agent or other person acting on the Company’s behalf in order to gain any commercial, contractual or regulatory advantage for the Company in a way which is unethical in order to gain any personal advantage, pecuniary or otherwise for the individual or anyone connected with the individual.
  • making unofficial payments to officials; or
  • appointing any third party or supplier to act on behalf of the Company whom is known or there is good reason to believe has engaged in any corrupt or unlawful conduct including any offences under the Act.

Gifts and Hospitality

Gifts and entertainment given and received as a reward, inducement or encouragement for preferential treatment or inappropriate or dishonest conduct are strictly prohibited. In particular, no gifts, hospitality or entertainment may be given or accepted during contractual negotiations if there is any realistic risk that such gifts or entertainment could influence the outcome of such processes or negotiations.

This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:

  • normal and appropriate hospitality
  • the giving of a gift for a corporate reason or at another special time, as long as reported in the proper manner within the firm on the gifts register

Before appointing a new supplier or entering into a new contract, appropriate due diligence should be conducted.

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Information contained on this website is not intended for retail investors. It contains details on Haibun Partners LLP services and products and is intended for elective professional clients only, therefore promotion of such products and services is restricted.

Haibun Partners LLP recommend that investors seek specialist tax or financial advice before investing. Haibun Partners LLP do not provide advice and the information on this website should not be construed as such.

Any tax relief referred to may be subject to change and will depend on an investors individual circumstances. Please note that any reference made to past performance is not a reliable indicator of future results.

This Website is published solely for informational purposes and has no regard to the specific investment objectives, financial situation or particular needs of any person.

Loss of protection warning:

A number of rules and protections which would otherwise apply to you will not apply if you are accepted to be treated as a professional client.

In particular:

  1. Communications, including financial promotions made by us, with professional clients are not subject to all of the requirements imposed by MiFID on communications with retail clients. Our communications must be clear, fair and not misleading. We may take into account your expertise as an elective professional client when complying with the requirements to provide you with a general description of the nature and risks of particular transactions.
  2. We will assume that an individual has an understanding of risk in relation to the products, transactions and services if classified as a professional client, and that you have the necessary level of experience and knowledge to understand the risks involved, and that you are able financially to bear the investment risks.
  3. Professional clients may not be eligible complainants with respect to the Financial Ombudsman Services.
  4. Information provisions about us, our services, and remuneration that are required with retail clients are not all required with respect to professional clients.
  5. With respect to non-advised services, we are not required to request information or adhere to the same procedures when assessing the appropriateness of a given service or product for a professional client.
  6. Generally, only retail clients are entitled to claim compensation under the Financial Services Compensation Scheme.

Haibun Partners LLP is directly authorised and regulated by the Financial Conduct Authority, registration number 440399.

Please confirm you have read the above warnings and are happy to proceed on the basis that Haibun Partners LLP will only deal with you on the basis that you will need to be accepted as an elective professional client. For further details on the professional client categorisation please view the section of the FCA’s handbook here.

https://www.handbook.fca.org.uk/handbook/COBS/3/5.html