Company Policies

Policy Statement

 

It is the policy of Hood Gaming Limited (the Company) to conduct business in an honest and ethical manner. As part of that, the Company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates and implementing and enforcing effective systems to counter bribery.

Purpose

The Company will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad.

Scope and applicability

This policy applies to all individuals working for or on behalf of the Company at all levels and grades, whether permanent, fixed-term or temporary, and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of the Company, (collectively referred to as Workers in this policy).

In this policy, Third Party means any individual or organisation that Workers come into contact with during the course of work and the running of the Company’s business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.

What is bribery?

A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely:

giving or offering a bribe;

receiving or requesting a bribe; or

bribing a foreign public official.

The Company may also be liable under the Act if it fails to prevent bribery by an associated person (including, but not limited to Workers) for the Company’s benefit.

Gifts and hospitality

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, we have specific internal policies and procedures which provide guidance to Workers as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below (the Overriding Principles), namely that any gift or hospitality must not be made with the intention of improperly influencing a Third Party or Worker to obtain or retain business

or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

must comply with local law in all relevant countries;

must be given in the name of the organisation, not in an individual’s name; • must not include cash or a cash equivalent;

must be appropriate in the circumstances;

must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift;

must be given openly, not secretly; and

in the case of gifts, they must not be offered to, or accepted from, government officials or representatives, politicians or political parties, without the prior approval of either the Company’s Board.

The Company appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.

What is not acceptable?

It is not acceptable for any Worker (or someone on their behalf) to:

give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or the Company will improperly be given a business advantage, or as a reward for a business advantage already improperly given;

give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;

accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;

accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by the Company in return;

threaten or retaliate against another Worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

engage in any activity that might lead to a breach of this policy.

Facilitation payments and “kickbacks”

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.

Charitable Donations and Sponsorship

The Company only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with the Company’s internal policies and procedures.

Record keeping

We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.

Responsibilities and raising concerns

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy

Workers are required to notify the Company as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee Workers if they breach this policy.

If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with the Company’s Anti-Bribery Compliance Team at privacy@hoodseating.com

EQUAL OPPORTUNITIES POLICY

A) STATEMENT OF POLICY

Hood Gaming Limited (The Company) recognises that we live in a society where discrimination still operates to the disadvantage of many groups in society.

The Company believes that all persons should have equal rights to recognition of their human dignity, and to have equal opportunities to be educated, to work, receive services and to participate in society.

We are committed to the promotion of equal opportunities within the Company, through the way we manage the organisation and provide services to the community. In order to express this commitment, we develop, promote and maintain policies that will be conductive to the principles of fairness and equality in the workplace.

The objective of this policy is that no person should suffer or experience less favourable treatment, discrimination or lack of opportunities on the grounds of gender, race, colour, nationality, ethnic origin, religious or philosophical beliefs, health status, HIV status, age, marital status, parental status, sexual orientation, political beliefs or trade union membership, class, responsibility for dependents, physical attributes, ex-offender status as defined by the Rehabilitation of Offenders Act 1974, lack of formal qualifications where such qualifications are not formally required, or any other grounds which cannot be shown to be justifiable within the context of this policy.

This policy will influence and affect every aspect of activities carried out at The Company i.e. promotional work, educational services, casework and other functions linked to the Company, as determined by the Board of Directors.

In the provision of services and the employment of staff, the Company is committed to promoting equal opportunities for everyone. Throughout its activities, the Company will treat all people equally whether they are:

Seeking or using our products and services. ƒ

Applying for a job or already employed by us. ƒ

Trainee workers and students on work experience or placements.

B) How the policy will be implemented and who is responsible?

The Board of Directors has specific responsibility for the effective implementation of this policy. We expect all our employees to abide by the policy and help create the equality environment which is its objective.

In order to implement this policy we shall:

Communicate the policy to employees, job applicants, volunteers and relevant others.

Incorporate specific and appropriate duties in respect of implementing the equal opportunities policy into job descriptions and work objectives of all staff. ƒ

Ensure that those who are involved in assessing candidates for recruitment or promotion will be trained in nondiscriminatory selection techniques. ƒ

Incorporate equal opportunity notices into general communications practices. ƒ

Ensure that adequate resources are made available to fulfil the objectives of the policy.

Conduct and general standards of behaviour

All staff are expected to conduct themselves in a professional and considerate manner at all times. The Company will not tolerate behaviour such as:

making threats

physical violence

shouting

swearing at others

persistent rudeness

isolating, ignoring or refusing to work with certain people

telling offensive jokes or name-calling

displaying offensive material such as pornography or sexist/racist cartoons, or the distribution of such material via email/text message or any other format.

any other forms of harassment or victimisation.

The items on the above list of unacceptable behaviours are considered to be disciplinary offences within the company and can lead to disciplinary action being taken. The Company does, however, encourage staff to resolve misunderstandings and problems informally wherever possible, depending on the circumstances. However, whether dealt with informally or formally, it is important for staff who may have caused offence to understand that it is no defence to say that they did not intend to do so or to blame individuals for being over-sensitive. It is the impact of the behaviour, rather than the intent, that counts, and that should shape the solution found both to the immediate problem and to prevent further similar problems in the future.

Complaints of discrimination

The Company will treat seriously all complaints of unlawful discrimination on any forbidden grounds made by employees, directors, clients or other third parties and will take action where appropriate.

All complaints will be investigated in accordance with the organisation's grievance, complaints or disciplinary procedure, as appropriate and the complainant of the outcome in line with these procedures.

We will also monitor the number and outcomes of complaints of discrimination made by staff, directors, clients and other third parties.

C) Legal Obligations

Equal Opportunities and Discrimination (Equality Act 2010) The new Equality Act came into force in October 2010 and replaces all previous equality legislation in England, Scotland and Wales ² namely the Race Relations Act 1976, the Disability Discrimination Act 1995, the Sex Discrimination Act, the Equal Pay Act, the Employment Equality (Age) Regulations 2006, The Civil Partnership Act 2004, the Employment Equality Regulations 2003 (religions and belief and sexual orientation).

The Equality Act 2010 protected characteristics are:

Age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race , religion or belief sex and sexual orientation.

In valuing diversity the Company is committed to go beyond the legal minimum regarding equality.

The Equality Act 2010 harmonises and strengthens and replaces most previous equality legislation. The following legislation is still relevant:

The Human Rights Act 1998.

The Work and Families Act 2006.

Employment Equal Treatment Framework Directive 2000 (as amended).

D) RECRUITMENT AND SELECTION

The recruitment and selection process is crucially important to any equal opportunities policy. We will endeavour through appropriate training to ensure that employees, making selection and recruitment decisions will not discriminate, whether consciously or unconsciously, in making these decisions.

Promotion and advancement will be made on merit and all decisions relating to this will be made within the overall framework and principles of this policy.

Job descriptions, where used, will be revised to ensure that they are in line with our equal opportunities policy. Job requirements will be reflected accurately in any personnel specifications.

We will adopt a consistent, non-discriminatory approach to the advertising of vacancies.

All applicants who apply for jobs with us will receive fair treatment and will be considered solely on their ability to do their job.

Short-listing and interviewing will be carried out by more than one person where possible.

Interview questions will be related to the requirements of the job and will not be of a discriminatory nature.

Selection decisions will not be influenced by any perceived prejudices of other staff.

E) MONITORING

1. We will maintain and review the employment records of all employees in order to monitor the progress of this policy.
2. Monitoring may involve - The collection and classification of information regarding the race in terms of ethnic/national origin and sex of all applications and current employees

The examination by ethnic/national origin and sex of the distribution of employees and the success rate of the applicants; and

Recording recruitment, training and promotional records of all employees, the decisions reached and the reason for those decisions.

2. The results of any monitoring procedure will be reviewed at regular intervals to assess the effectiveness of the implementation of this policy. Consideration will be given, if necessary, to adjusting this policy to afford greater equality of opportunities to all applicants and staff.

The board of Directors will revise and review this policy regularly. Approved by the board on 2nd January 2025.

Hood Gaming Ltd

Hood Gaming are committed to this policy and will conduct business in an ethical, legal and socially responsible manner. This commitment extends to suppliers and other associated external resources with which we chose to do business. We will purchase goods and services to the highest standards of ethical and environmental trade practices including the provision of safe working conditions and the protection of workers across our supply chain. Hood Gaming conducts business in accordance with the Ethical Trading Initiative Base Codes.

Our policy is committed to:

• Act in an ethical manner and comply with statutory and legal requirements, promoting good labour and ethical standards in the supply chain of goods and services.
• Form an evaluation and selection criteria for all goods purchased by, and services provided to Hood Gaming through detailed analysis of external providers, researched and documented information.
• Encourage suppliers to follow a Code of Conduct based on the code developed by the Ethical Trading Initiative (ETI), which is an alliance of companies, non-governmental organisations and trade union members who are working towards worldwide ethical standards of trading. Whilst Hood Gaming is not a full member of the Ethical Trading Initiative alliance, Hood Gaming fully endorses its principles.

This policy forms a formal part of the organisation's quality management principles and will be subsequently communicated and reviewed at regular intervals. The policy will be communicated to all relevant internal and external parties within the business. It is our commitment to continually improve through monitoring and measuring the resulting objectives and targets and the programme management of this policy.