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This Policy applies to all directors and employees of Halfords Group Plc and its subsidiaries (together the "Group", or "Halfords")

Chief Executive Officer's Commitment

At Halfords, we are fully committed to supporting global endeavours to combat all forms of Bribery and Corruption. This both reflects our Group commitment to comply with all relevant legal and regulatory frameworks, and clearly demonstrates our intrigity, transparency and ethical practice.

This Anti-Bribery and Corruption Policy therefore serves to explain how we effectively enable the Halfords Group to observe anti-Bribery and anti-Corruption laws wherever our colleagues are working around the world. It also aims to ensure that any other party or organisation that is acting on our behalf or in our name, applies the same rigour in its operational business.

If colleagues are uncertain about any aspect of this Policy, or if they need further advice, guidance or support, they are advised to contact the Halfords’ Company Secretary at legal.dept@halfords.co.uk.

Graham Stapleton
Chief Executive Officer

23 March 2021

Policy

Appendix 1: Guidance

Colleagues must observe the following guidance in respect of receiving or giving gifts and hospitality. Remember, even when following this advice, colleagues must still complete the Group’s Gift Register.

(i) Receiving Gifts / Samples

1) Never accept or offer monetary gifts.

2) Never give the impression that the award of business is conditional upon gifts or hospitality, or ask / encourage a third party to provide a gift or hospitality.

3) Gifts received from suppliers must never be accepted on a personal basis and must instead be placed in a raffle for charity, other than (i) low value items such as pens, calendars, mugs and diaries that carry a company logo, which can be retained by colleagues; or (ii) low value gifts where receipt is a local/cultural tradition and it would be impolite to decline (e.g. in China), provided that the gift has been pre-approved by the colleague’s Line Manager

4) Gifts must be delivered to a work location, and not to a colleague’s home / alternative address.

5) Samples received from suppliers will not become the personal property of any individual, unless purchased through a properly organised sample sale. Samples may be removed for evaluation as part of a colleague’s role (and returned at the end of the evaluation), but only where Line Manager’s approval is obtained through the existing samples logging system.

(ii) Giving Gifts

1) Never offer or give a gift to a Public Official, including Foreign Public Officials.

2) Never make a cash payment to a Public Official other than in an official capacity.

(iii) Hospitality

1) For certain roles, it will be appropriate to have dinner with a supplier (e.g. when on a foreign trip or at an exhibition).

2) Meals and entertainment (including sporting/music events) are acceptable provided they are:

  • incidental to a business-related event(s);
  • reasonable in value;
  • given in good faith;
  • permitted under local laws and customs;
  • offered infrequently; and
  • approved by a Line Manager prior to the activity and recorded on the appropriate form submitted to the Company Secretary.

3) Gifts or hospitality should always be avoided whilst any tendering process is underway or any contract or engagement is being negotiated.

4) Where hospitality is being offered, Halfords should seek to pay and/or reciprocate at least half of the time and when more than one colleague is involved and Halfords is paying, the most senior employee must pay. Any such payment may be recoverable as expenses but only if it is incurred in accordance with the Expenses Policy.