At Elcometer we are committed to protecting and respecting your privacy.

Our privacy policy explains what personal information we collect, why we collect it, how we use it, the control you have over it and how we protect it. This privacy notice applies to personal information we collect through our Elcometer websites, or which is provided by you in person (for example when you visit our offices, exhibition stands or events).

It is important you read this privacy notice, together with any terms and conditions we may provide or make available to you from time to time. This privacy notice supplements the other notices and is not intended to override them.

By sharing your personal information with us, or by continuing to use our websites, you confirm that you have read and understood the terms of this privacy policy. We take responsibility for the personal information we collect about you, and we aim to be transparent about how we handle it, and give you control over it.

For details on Elcometer’s Privacy Policy, please click on the drop down list below.

Purpose

This policy sets out the responsibility of Elcometer Ltd as a corporate entity (including all subsidiary businesses wherever located), and all employees of Elcometer and its subsidiaries (hereafter referred to as the “Group”) in observing and upholding the Group’s position on bribery and corruption.

It also provides information and guidance to all employees of the Group on how to recognise and deal with bribery and corruption issues.

Policy Statement

It is the Group’s policy to conduct all business in an honest and ethical manner. A zero-tolerance approach to bribery and corruption is taken by the Group and it is committed to acting professionally, fairly and with integrity in all dealings wherever it operates. The Group is committed to implementing and enforcing effective systems to counter bribery.

Legislation

The Bribery Act 2010 became part of UK law on 1^st July 2011.

Bribery is now punishable for both individuals (up to ten years’ imprisonment and unlimited fines) and corporate entities (unlimited fines). In addition, it is now an offence for corporate entities to fail to prevent bribery.

This applies to all UK businesses and any other business, wherever registered, if it carries on any business in the UK or is managed by people with a UK connection. As such this applies as much to Elcometer Ltd’s overseas subsidiaries as it does to the UK business.

Who is covered by the policy?

This policy applies to all employees (whether permanent, fixed-term or temporary), consultants, contractors, agency staff or any other person providing services to the Group (collectively referred to as “workers” hereafter).

What is bribery?

A bribe is a financial or other advantage offered or given to a person in order to gain a commercial, contractual or personal advantage. (For the avoidance of doubt, this does not include discounting of product).

Under the Bribery Act 2010, it is an offence to bribe another or to receive a bribe. In addition, however, no money needs to have changed hands for people to be caught under the Act – a person can be guilty of an offence if they offer/promise to pay or request/agree to receive a financial or other advantage.

Gifts and Hospitality

The Group will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence any commercial or public official in the performance of their duties. The Group will not make contributions of any kind to political parties and no charitable donations will be made for the purpose of gaining any commercial advantage.

This policy does not prohibit the giving and receiving of promotional gifts of low value and normal and appropriate hospitality. As stated in the Elcometer Ltd Staff Handbook however, the offer of gifts or entertainment in excess of ?50 must not be accepted without the prior approval of a Director.

Gifts or hospitality given or received must be reasonable and justifiable. The following points are intended as guidelines in this respect:

• Gifts or hospitality are not made with the intention of influencing 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;
• it is not an unlawful gift;
• it is given in the name of the business and not in an individuals name;
• it does not include cash or a cash equivalent (such as gift certificates or vouchers);
• it is appropriate in the circumstances (for example, small gifts given at Christmas time);
• taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time;
• it is given openly, not secretly.

Record-keeping

The Group will keep financial records and have appropriate internal controls in place which will evidence the business reason for making any payments to third parties.

Workers must ensure all expense claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with the expenses policy in force at each business and must specifically record the reason for the expenditure.

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

Workers responsibilities

All workers must ensure that they read, understand and comply with this policy at all times.

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

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

Raising Concerns

Workers are encouraged to raise concerns to a Company Director about any issue or suspicion of malpractice at the earliest possible stage.

No worker will suffer any detrimental treatment as a result of either refusing to take part in bribery or as a result of raising genuine concerns about bribery, even if these turn out to be mistaken. (Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern).

Monitoring

The Board of Directors has overall responsibility for ensuring the effectiveness of this policy.

Internal control systems and procedures will be subject to regular audits to provide assurance that these are effective in countering bribery.

All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

As an international organisation, Elcometer Limited sources products and components from around the Globe. Our environmental and anti-bribery policies clearly state our position on these two very important issues and go some way to set out our position on how we conduct our business in a sustainable and ethical way.

This Ethical Procurement Policy has been written to further describe how we conduct business with our suppliers, together with the expectations that we have of our suppliers regarding the way that they conduct their business and applies to all Elcometer’s purchases of goods and services.

Our aim is to ensure that the whole of our supply chain conforms to our ethical procurement standards.

As a leading supplier of inspection equipment, we understand that our reputation does not simply rest with the quality and service we offer to our customers. We have a duty to ensure that we strive to maintain the highest standards of ethical conduct and corporate responsibility worldwide and seek to influence our suppliers to operate to similar high standards as ourselves.

We support the principles set out within the United Nations Universal Declaration of Human Rights and the principles set out in the Dodd Frank Wall Street Reform and Consumer Protection Act, Section 1502 with regards to the use of conflict minerals.

Elcometer will:

• expect all our employees to adhere to our environmental, anti-bribery and ethical procurement policies;
• pay suppliers in accordance with the agreed terms and deal with exceptions in a timely manner;
• ensure that we will not knowingly purchase product(s) which contain metals derived from minerals defined as ‘Conflict Minerals.’ Conflict Minerals include columbite-tantalite (coltan, niobium and tantalum), cassiterite (tin), gold, wolframite (tungsten), their derivatives or other minerals determined by International Governments to be financing conflict.
• ensure an ethical basis to business practice;
• select and treat our suppliers fairly and objectively at all times;
• seek to ensure that our environmental, anti-bribery and ethical procurement policies are considered in our supplier appraisal process.

We expect our suppliers to:

• conduct business without the payment or receipt of inducements, unlawful incentives or other benefits that might be considered an attempt to influence decision makers;
• respect fundamental human rights;
• treat employees fairly, never abuse or threaten them and never use forced, bonded or child labour;
• maintain a safe working environment at all times and provide access to protective equipment and safety training for all employees;
• confirm they understand and respect our environmental, anti-bribery and ethical procurement policies;
• maintain effective policies, processes and procedures to manage their environmental impact and to operate their business in a sustainable way;
• ensure that they do not purchase products which contain metals derived from conflict minerals;
• comply with all applicable local, national, regional and international laws, regulations and directives at all times; and
• respect the intellectual property rights of others.

Monitoring

The Board of Directors has overall responsibility for ensuring the effectiveness of this policy.

All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

Conflict Minerals Statement

The U.S. Securities and Exchange Commission (SEC) has imposed obligations relating to conflict minerals under the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010, brought into effect in January 2013. US Congress has the sense that the exploitation and trade of conflict minerals in the Democratic Republic of the Congo (DRC) is helping to finance conflict characterised by extreme levels of violence.

The Act defines conflict minerals as cassiterite (tin), coltan (tantalum), wolframite (tungsten) and gold, or derivatives of these minerals. Sometimes these minerals are referred to as the ‘three Ts’ – tin, tantalum and tungsten (and gold).

Elcometer Limited supports ending the violence and human rights violations in the mining of minerals from the ‘Conflict Region’ and is working with its customers and suppliers to ensure compliance with these requirements.

We support the aims and objectives of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010 and ask our suppliers to undertake reasonable control with their supply chains. Our due diligence process requires suppliers to provide a written declaration on use of conflict materials and operate in accordance with the Conflict-Free Smelter (CFS) Program.

Elcometer will not knowingly procure specified materials that are not certified as ‘conflict-free’. In the event that suppliers are not following these guidelines Elcometer will act to resolve this and transition products to be ‘conflict free’.

Elcometer ISO14001 Certificate

Protection of our environment is an integral part of Elcometer’s activities.  We take a responsible approach to environmental management throughout our Company, with our Board of Directors being responsible for our environmental performance.

We are committed to the achievement of the expectations of our customers and stakeholders through the alignment of our environmental objectives to our programme of continuous improvement in order to reduce our total impact on the environment.

• All relevant compliance obligation requirements are met
• Environmental performance is monitored and reviewed on a regular basis
• Any emissions to air, releases to water, energy usage or disposal of solid waste to landfill does not cause unacceptable environmental effects
• Our business is conducted in a way that respects our neighbours

Introduction

This statement sets out Elcometer Limited’s actions to understand all potential modern slavery risks related to its business (in pursuant to s.54 of the Modern Slavery Act 2015). It puts in place steps that are aimed at ensuring that there is no slavery or human trafficking across Elcometer’s business or its wider supply chain.

This statement relates to actions and activities during the financial year ending 31 March 2022.

As part of the spray, dry abrasive blast, coatings inspection & ultrasonic NDT inspection equipment industry sectors, Elcometer recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Elcometer is absolutely committed to preventing slavery and human trafficking in all of its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Countries of operation and supply

Elcometer is a world leader in the design, manufacture and supply of spray, dry abrasive blast, coatings inspection & ultrasonic NDT inspection equipment primarily into the automotive, protective and industrial finishing industries. Ever since the first Elcometer gauge was manufactured in 1947, our philosophy has been to provide industry leading, innovative, high quality products; supported by a best-in-class customer experience at a competitive price. By concentrating on these core values, Elcometer has grown into a global network with representation worldwide.

Our headquarters and primary manufacturing operation is based in Manchester UK, with additional manufacturing operations at our subsidiary businesses in California, USA and Vitoria, Spain. In addition to our UK headquarters, we have direct sales, support and repair facilities in France, Germany, Japan, Singapore, The Netherlands, The UAE and USA, together with a global distribution network with representation in approximately 170 countries.

We work with approximately 950 suppliers with the majority based in the UK and across the European Union. We do not source goods from high risk countries where modern forms of slavery are prevalent.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Ethical Procurement policy: this policy sets out our approach to conducting business with our suppliers together with the expectations that we have of our suppliers regarding the way that they conduct their business and applies to all Elcometer’s purchases of goods and services.
2. Recruitment policy: we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
3. Open door policy: we operate an open-door policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
4. Our company values: these values are core to our business and explain the manner in which we behave as an organisation and how we expect our employees and suppliers to act. These hold employees accountable for their actions and require them to act in an ethical manner.
5. Supplier assessments: we operate a supplier selection and appraisal programme and maintain an approved supplier list. We conduct due diligence on suppliers before granting them a preferred supplier status. This due diligence includes an online search to ensure that the particular organisation has never been convicted of offenses relating to modern slavery and may include on-site audits dependent on risk associated with the nature of supply and supplier location.

Responsibility

Responsibility for Elcometer’s anti-slavery initiatives is as follows:

• Policies: All company policies are developed by Elcometer’s Management Team and approved by the Board of Directors. Policies are audited and reviewed in line with our ISO 9001 procedures.
• Risk assessments, investigations/due diligence: All relevant assessments are made by the appropriate departmental head, including those in relation to human rights and modern slavery. Any concerns are raised with the Board of Directors.
• Training: Our procurement team has received training so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Due diligence

Elcometer undertakes due diligence during supplier selection and periodic reviews of our existing suppliers. Our processes include:

• A robust and proportionate approach to supplier assessment, considering the nature of the supply into our business and the associated risks;
• Evaluating the modern slavery and human trafficking risks of our suppliers of products, using information from the Global Slavery Index to identify higher risk industries and countries of supply;
• Conducting supplier audits and assessments to include Modern Slavery

Any supplier who fails to meet our performance evaluations will be removed as a preferred supplier and we will terminate our business relationship with the supplier until such time as they can provide proof that they adhere to our policies and requirements as listed above.

Performance indicators

Elcometer communicates with our supply chain to ensure that they are in compliance with our policies and to ensure that slavery and/or human trafficking is not taking place within our business or supply chain. Any reports received from the public, employees or law enforcement agencies which indicate that modern slavery practices have been identified will also be acted upon in the appropriate manner.

Awareness-raising programme

Elcometer has raised awareness of modern slavery issues by putting up posters across our premises, circulating this policy via email to all employees and advising staff how they can report any potential issues with regards to slavery and human trafficking.

Board approval

This statement was approved on 29th September 2022 by Elcometer’s Board of Directors who review and update it annually.

M.C. Sellars

In light of the Criminal Finances Act 2017, Elcometer Limited (“Elcometer”) has adopted this corporate value statement and policy relating to the anti-facilitation of tax evasion.

We request all our employees, and other individuals and businesses who have, or seek to have, a business relationship with Elcometer and/or any member of our Group, to familiarise themselves with our anti-facilitation of tax evasion value statement and to act at all times in accordance with this policy.

ANTI-FACILITATION OF TAX EVASION VALUE STATEMENT

Elcometer and its subsidiaries (the “Company”, “we”, “our”) take a zero tolerance approach to all forms of tax evasion and the facilitation of tax evasion, whether under UK law or under the law of any foreign country.

It is our policy to conduct all of our business dealings in an honest and ethical manner. This value statement governs all our business dealings and the conduct of all our employees and persons or organisations who are appointed to act on our behalf. At all times, business should be conducted in a manner such that the opportunity for, and incidence of, tax evasion is prevented.

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 tax evasion facilitation.

We will uphold all laws relevant to countering tax evasion, including the Criminal Finances Act 2017.

WHO MUST COMPLY WITH THIS POLICY?

This policy applies to all persons working for the Company or any Group company and acting on our behalf in any capacity, including employees at all levels, directors, Associates (as defined below), and including but not limited to agency workers, seconded workers, volunteers, interns, contractors, external consultants, third-party representatives and business partners, sponsors or any other person associated with us, wherever located.

WHO IS RESPONSIBLE FOR THIS POLICY?

The Board of Directors of the Company has overall responsibility for ensuring that this policy complies with our legal obligations, and that our employees and Associates comply with it. This policy is adopted by the Company. It may be varied or withdrawn at any time, in the Company’s absolute discretion. Employees in management or leadership positions are responsible for ensuring those reporting to them understand and comply with this policy.

WHAT IS THE FACILITATION OF TAX EVASION?

For the purposes of this policy:

Associates includes company contractors or an agent of the Company (other than a contractor) who is acting in the capacity of an agent, or any person who performs services for and on behalf of the Company who is acting in the capacity of a person or business performing such services.

Tax Evasion means an offence of cheating the public revenue or fraudulently evading UK tax, and is a criminal offence. The offence requires an element of fraud, which means there must be deliberate action, or omission with dishonest intent.

Foreign Tax Evasion means evading tax in a foreign country, provided that the conduct is an offence in that country and would be a criminal offence if committed in the UK. As with tax evasion¸ the element of fraud means there must be deliberate action, or omission with dishonest intent.

Tax Evasion Facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax whether UK tax or tax in a foreign country by another person, or aiding, abetting, counselling or procuring the commission of that offence. Tax Evasion Facilitation is a criminal offence, where it is done deliberately and dishonestly.

Tax means all forms of UK taxation, including but not limited to corporation tax, income tax, value added tax, stamp duty, stamp duty land tax, national insurance contributions (and their equivalents in any non-UK jurisdiction) and includes duty and any other form of taxation (however described).

Third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisers, representatives and officials, politicians and political parties.

Under the Criminal Finances Act 2017, a separate criminal offence is automatically committed by a corporate entity or partnership where the Tax Evasion is facilitated by a person acting in the capacity of an “associated person” to that body. For the offence to be made out, the associated person must deliberately and dishonestly take action to facilitate the Tax Evasion by the taxpayer. If the associated person accidentally, ignorantly, or negligently facilitates the Tax Evasion, then the corporate offence will not have been committed. The Company does not have to have deliberately or dishonestly facilitated the Tax Evasion itself; the fact that the associated person has done so creates the liability for the Company.

Tax evasion is not the same as tax avoidance or tax planning. Tax evasion involves deliberate and dishonest conduct. Tax avoidance is not illegal and involves taking steps, within the law, to minimise tax payable (or maximise tax reliefs).

WHAT EMPLOYEES AND ASSOCIATES MUST NOT DO

It is not acceptable for employees and Associates (or someone acting on behalf of the employee or Associate) to:

a) engage in any form of facilitating Tax Evasion or Foreign Tax Evasion;

b) aid, abet, counsel or procure the commission of a Tax Evasion offence or Foreign Tax Evasion offence by another person;

c) fail to promptly report any request or demand from any third party to facilitate the fraudulent Evasion of Tax by another person, in accordance with this policy;

d) engage in any other activity that might lead to a breach of this policy;

e) threaten or retaliate against another individual who has refused to commit a tax evasion offence or a Foreign Tax Evasion offence or who has raised concerns under this policy;

f) commit an offence under the law of any part of the UK consisting of being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax.

PREVENTION THROUGH VIGILANCE – EMPLOYEE AND ASSOCIATE RESPONSIBILITY

Employees and Associates must at all times adhere to this value statement and policy, and must ensure that they read, understand and comply with this policy.

The prevention, detection and reporting of Tax Evasion and Foreign Tax Evasion are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

There is not an exhaustive list of Tax Evasion opportunities. At a more general level, the best defence against Tax Evasion and the facilitation of Tax Evasion remains the vigilance of our employees and Associates, and the adoption of a common-sense approach supported by our clear whistleblowing procedure. In applying common sense, employees must raise the following questions or report any of the following issues/concerns in the course of their day to day work:

• is there anything unusual about the manner in which an Associate of the Company is conducting their relationship with the Company or a Third Party (usually a customer)?
• is there anything unusual about a customer’s or an Associate’s conduct or behaviour in your dealings with them?
• are there unusual payment methods that have been requested or used? Unusual payment methods and unusual conduct of Third Parties with Company Associates can be indicative that a transaction may not be as it seems.
• you become aware, in the course of your work, that a Third Party has deliberately failed to register for VAT (or the equivalent tax in any relevant non-UK jurisdiction) or failed to account for VAT.
• a Third Party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made.
• you become aware, in the course of your work, that a Third Party working for us as an employee asks to be treated as a self-employed contractor, but without any material changes to their working conditions.
• a Third Party to whom we have provided goods requests that their invoice is addressed to a different entity, where we did not provide goods to such entity directly.
• a Third Party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us.

HOW TO RAISE A CONCERN

Employees are encouraged to raise concerns about any issue or suspicion of Tax Evasion or Foreign Tax Evasion as soon as possible.

If there is any suspicion of any intention that an employee, Associate or Third Party is attempting to, or is committing Tax Evasion or Foreign Tax Evasion, the details of the parties and the transaction must be reported to the Company’s finance department, as soon as possible, who will report the circumstances to HMRC.

If you are unsure about whether a particular act constitutes Tax Evasion or Foreign Tax Evasion, raise it with the contacts detailed below as soon as possible. You should note that the corporate offence is only committed where you deliberately and dishonestly take action to facilitate the Tax Evasion or Foreign Tax Evasion. If you do not take any such action, then the offence will not be made out. However, a deliberate failure to report suspected Tax Evasion or Foreign Tax Evasion, or “turning a blind eye” to suspicious activity could amount to criminal facilitation of tax evasion.

Any queries or suspicions should be directed to the following personnel: Gary Stewart – Group Finance Director Nicki Campbell – Group HR and Organisational Development Director

WHAT HAPPENS IF THE EMPLOYEE PREFERS, FOR COMMERCIAL REASONS, NOT TO REPORT THEIR SUSPICIONS?

This should never happen. If we, as an employer, fail to prevent our employees, workers, agents or service providers from facilitating Tax Evasion, and if there is any suspicion of any intention to evade tax and the transaction is nevertheless finalised, the Company can be criminally prosecuted, subject to a large fine and be publicly named and shamed causing damage to our reputation. We therefore take our legal responsibilities seriously.

Individuals 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.

TRAINING AND COMMUNICATION

Training on this policy will be provided as necessary. Such training may form part of wider financial crime detection and prevention training.

Our zero-tolerance approach to Tax Evasion or Foreign Tax Evasion must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate after that.

BREACHES OF THIS POLICY

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals, Associates and organisations working on our behalf if they breach this policy.