Harneys Fiduciary Anti-Bribery and Anti-Corruption Policies and Procedures set out the policies and procedures for identifying, preventing and avoiding corruption and bribery for Harneys Fiduciary Limited, Harneys Fiduciary Cyprus Limited and each of their direct and indirect subsidiaries (collectively, Harneys Fiduciary).
The policies and procedures apply to all persons involved in Harneys Fiduciary business, including people working on Harneys Fiduciary’s behalf, managers, shareholders, officers and directors (collectively referred to as employees).

It is the policy of Harneys Fiduciary to conduct all its business in an honest and ethical manner. Harneys Fiduciary takes a zero tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever Harneys Fiduciary operates.

Harneys Fiduciary and its employees (or someone on the employee’s behalf) must not engage in any activity that might lead to a breach of its Anti-Bribery and Anti-Corruption Policies and Procedures.

An Anti-Bribery Committee has been established which is responsible for implementing the requirements of the policies and procedures, including considering applications and investigating reports, monitoring effectiveness and arranging adequate and regular training.

Harneys Fiduciary does not make, and will not accept, facilitation payments or ‘kickbacks’ of any kind.

Harneys Fiduciary and its employees (or someone on the employee’s behalf) must not give, promise to give, or offer, a payment, gift or hospitality (except normal and appropriate gifts or hospitality as set out in the policies and procedures) (i) with the expectation or hope that a business advantage will be received, or (ii) to reward a business advantage already given; or (iii) to a government official, agent or representative to ‘facilitate’ or expedite a routine procedure.

Harneys Fiduciary and its employees (or someone on the employee’s behalf) must not accept a payment, gift or hospitality (except normal and appropriate gifts or hospitality as set out in the policies and procedures) from a third party that an employee knows or suspects is offered or provided with an expectation that a business advantage will be provided by Harneys Fiduciary in return.

Harneys Fiduciary reserves the right to review each situation as it arises and may approve a specific gift or hospitality upon application to the Anti-Bribery Committee in accordance with the policies and procedures.

Harneys Fiduciary does not make contributions to political parties. Harneys Fiduciary only makes charitable donations that are legal and ethical under local laws and practices. Harneys Fiduciary has Corporate Social Responsibility Committees in each office which receive, review and decide upon all donation and sponsorship requests in accordance with its CSR policy, priorities and established practice.

Employees must adhere to the reporting and disclosure requirements set out in the policies and procedures. Harneys Fiduciary and its employees (or someone on the employee’s behalf) must not threaten or retaliate against another employee who has refused to commit a bribery offence or who has raised concerns under the policies and procedures.