December 2011 Summary The Bribery Act 2010 This circular sets out the Association’s policy for the prevention of bribery and corruption, which was approved by the Committee at its meeting in October 2011. Members should be familiar with the policy to ensure that they and the Association remain compliant with the new anti-bribery legislation. The policy statement: • Affirms the Association’s zero-tolerance to bribery and corruption; • Sets out in summary the procedures that the Association has in place to minimise the risk that it will become involved in bribery and corruption; • Explains the key role of Members, Correspondents and others who act on the Association’s behalf in combating corruption; • Explains how the policy will be monitored and reviewed over time. Any queries in relation to this circular should be addressed to your usual contact at the Managers.  The Britannia Steam Ship Insurance Association Limited Managers Tindall Riley (Britannia) Limited Regis House 45 King William Street London EC4R 9AN Tel +44 (0)20 7407 3588 Fax +44 (0)20 7403 3942 www.britanniapandi.com TO ALL MEMBERS Dear Sirs The Bribery Act 2010: Britannia's policy on the prevention of bribery and corruption This circular sets out the Association’s policy for the prevention of bribery and corruption, which was approved by the Committee at its meeting in October 2011. Members should be familiar with the policy to ensure that they and the Association remain compliant with the new anti-bribery legislation. The bribery threat and your obligations as a Member of Britannia 1. Recent years have seen increasing international efforts to combat bribery in all its forms. The United States Foreign Corrupt Practices Act was an example of this and, with its entry into force on1 July 2011, the United Kingdom's Bribery Act 2010 ("the Act") represents a further extension of anti-bribery legislation. Because the Act has a potentially worldwide impact, it is Britannia's policy that its Members and all providers of services to the Association comply strictly with the extensive anti-bribery regime that the Act requires (in addition to any local requirements). 2. This policy also extends to any service providers, including lawyers, experts, surveyors and any other form of agent, both those engaged directly by Britannia and those engaged by you in respect of any entry with Britannia or matter in which Britannia has an insured interest. 3. You must ensure that any service providers engaged by you in relation to any entry with Britannia or matter in which Britannia has an insured interest are aware of and understand the Association’s policy and the effect of the Act, and confirm to you that they will comply with it. 4. You are reminded that any individual or company that engages in bribery of any kind does so without the Association’s agreement or authority and that such activity is in clear contravention of the Association’s policy. The Act 5. What follows is a brief summary of the provisions of the Act and how they affect you; however, as with any summary, not all possible issues that might arise are covered. If you have any questions as to the applicability of the Act in any given circumstances, it may help you to refer to the Act itself. If that does not resolve your query, please consult us. 6. The three offences of which you most need to be aware are those under sections, 1, 2 and 6 of the Act. These are outlined below. Section 1: Bribing another person 7. It is an offence