Mammoth condemns corruption in all its forms and we will not tolerate it in our business or in those with whom we do business.

Our Anti-Corruption Code of Conduct sets out in detail how you should behave and what you should do if you encounter corruption in the course of your work with us. We expect that all of you will embrace the Code and its values and use them in all aspects of your day-to-day work.

The Code benefits you as much as it does Mammoth. If convicted of a bribery offence, Mammoth might get a significant fine and suffer lasting reputational damage. If you are convicted of a bribery offence, you could face up to ten years in prison.

If you have any doubts about anything at all, refer to the Code of Conduct or you can speak to James Penny in complete confidence.

1. POLICY STATEMENT

   1. It is our policy to conduct all of our business in an honest and ethical manner. We 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.

   2. The purpose of this policy is to:

      1. set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and

      2. provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

   3. Bribery and corruption are punishable for individuals by up to ten years' imprisonment and if we are found to have taken part in corruption we could face an unlimited fine and face damage to our reputation. We therefore take our legal responsibilities very seriously.

   4. In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes suppliers, contractors, artists, crew, business contacts, agents, consultants, advisers, broadcasters, distributors and financiers, government and public bodies, politicians and political parties (together with any advisors, representatives and officials of the above).

2. WHO IS COVERED BY THE POLICY?

   This policy applies to all individuals working for Mammoth Screen Limited or another Mammoth company, including company officers, employees (whether permanent, fixed-term or temporary), freelance crew, consultants, contractors, trainees, interns or any other person associated with us, wherever located (collectively referred to as workers in this policy).
   

3. WHAT IS BRIBERY?

   There are four main offences under the Bribery Act 2010: 

   ·         Giving a bribe;

   ·         Receiving a bribe;

   ·         Bribing a foreign public official; and

   ·        The corporate offence of failing to prevent bribery by an associated person for the organisation's benefit.

   A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
   
   

4. GIFTS AND HOSPITALITY

   1. We recognise that gifts and hospitality are sometimes a normal part of business. This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties.

   2. The giving or receipt of gifts and hospitality is not prohibited if, taking into account the reason for the gift/hospitality, it is of an appropriate type and value and given at an appropriate time. Gifts and/or hospitality cannot be given or received if the intention of such gifts or hospitality is to influence you or a third party 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.

   3. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
      

5. WHAT IS NOT ACCEPTABLE?

   It is not acceptable for you (or someone on your behalf) to:

   1. give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

   2. 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;

   3. accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;

   4. accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

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

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

6. FACILITATION PAYMENTS

   1. We do not make, and will not accept, facilitation payments of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. They are not commonly paid in the UK but could be common in a jurisdiction where we might film.

   2. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the line producer for your production (Line Producer), the production executive for your production (Production Executive), Jon Williams or James Penny.
      

7. DONATIONS

   We do not make contributions to political parties. No charitable donation must be offered or made without the prior approval of the Line Producer, Production Executive, Jon Williams or James Penny.
   

8. YOUR RESPONSIBILITIES

   1. You must ensure that you read, understand and comply with this policy.

   2. 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.

   3. You must notify the Line Producer, Production Executive, Jon Williams or James Penny as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a contractor or potential contractor offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their services or assistance.

   4. Any employee who breaches this policy will face disciplinary action, which could result in dismissal. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.
      

9. RECORD-KEEPING

   1. We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

   2. You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

   3. All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as contractors, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments
      

10. HOW TO RAISE A CONCERN

    You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, please speak to the Line Producer, Production Executive, Jon Williams or James Penny. Concerns should be reported straightaway.
    

11. WHAT TO DO IF YOU ARE A VICTIM OF BRIBERY OR CORRUPTION

    It is important that you tell your Line Producer, Production Executive, Jon Williams or James Penny as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
    

12. PROTECTION

    1. Workers who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

    2. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Production Executive, Jon Williams or James Penny immediately.
       

13. COMMUNICATION

    Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
    

14. WHO IS RESPONSIBLE FOR THE POLICY

    1. The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

    2. Jon Williams has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation.
       
       

15. MONITORING AND REVIEW

    James Penny will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. We will regularly audit our internal systems and procedures to make sure they are effective in countering bribery and corruption.