// ETHICAL POLICIES

Policy Statement

At Left Field, we are firmly committed to upholding the highest ethical standards and ensuring that slavery and human trafficking have no place in our operations or supply chains. This policy outlines our commitment to preventing modern slavery and human trafficking and the measures we take to address these issues.

Compliance with Legislation

In compliance with the Modern Slavery Act 2015, we are dedicated to showing the steps we have taken and the steps we plan to take to ensure that our business and our supply chains are free from slavery and human trafficking.

Organisational Structure and Supply Chain

Organisational Structure

Left Field operates within various sectors, including corporate events, charity functions, venue management, and private events. Given the nature of our business, we assess the risk of modern slavery and human trafficking as low. However, we remain vigilant and proactive in our approach.

Supply Chain

Our supply chain includes freelancers, consultants, and companies providing a diverse range of goods and services. We select suppliers based on their commitment to ethical practices and sustainable operations. We conduct thorough checks in line with our subcontractor quality policy to ensure they share our values and adhere to ethical standards.

Responsibilities

The Senior Management Team, alongside our Human Resources Consultant, is responsible for implementing this policy, conducting risk assessments, performing due diligence, and delivering training.

Our Actions

To ensure our commitment to preventing modern slavery and human trafficking, Left Field has implemented the following measures:

1. Policy Review and Development:
   • Regularly review and update our subcontractor quality policies to identify and address potential risks associated with modern slavery.
2. Creating an Open and Respectful Environment:
   • Foster a culture of respect and transparency where all employees are treated fairly.
   • Encourage open dialogue and whistleblowing to identify and report any concerns regarding modern slavery.
3. Risk Management of Suppliers:
   • Assess and monitor existing suppliers, particularly those providing staff services or employing non-UK nationals, or where high levels of physical labour are involved.
   • Implement additional due diligence where heightened risks are identified.
4. HR Policies and Procedures:
   • Ensure all staff have the right to work documents and are paid fairly, with competitive remuneration packages.
   • Adhere to stringent HR policies to protect our employees and prevent exploitation.
5. Training and Awareness:
   • Provide training for employees and management to raise awareness about modern slavery and human trafficking.
   • Ensure staff understand how to recognise and report any potential issues.
6. Due Diligence and Audits:
   • Conduct regular audits and reviews of our supply chain and operations to ensure compliance with this policy.
   • Take corrective actions where any non-compliance is identified.

Monitoring and Review

We are committed to continually reviewing and improving our approach to combating modern slavery. This includes:

• Regular Review:
  • Reviewing this policy at least annually to ensure its effectiveness and relevance.
• Feedback and Improvement:
  • Seeking feedback from employees and stakeholders to improve our practices.
• Adapting to Changes:
  • Updating our policy and procedures in response to new legislation, emerging risks, and operational changes.

Reporting Concerns

If you suspect any instance of modern slavery or human trafficking within our operations or supply chains, please report your concerns immediately:

• Internal Reporting:
  • Contact your line manager or use our whistleblowing channels.
• External Reporting:
  • Report to the relevant authorities if necessary.

Left Field is committed to ensuring that modern slavery and human trafficking are not part of our operations or supply chains. Through rigorous policies, continuous training, and effective monitoring, we aim to prevent any such practices and uphold the highest ethical standards. We encourage a culture of transparency and respect, ensuring that any concerns are addressed promptly and effectively.

Date of Last Revision: June, 2024

Introduction

At Left Field, we are dedicated to promoting diversity and equality in every facet of our organisation. We believe that everyone, regardless of gender, race, ethnic origin, disability, age, nationality, sexuality, religion or belief, marital status, or social class, deserves equal opportunities and fair treatment. This policy outlines our commitment to fostering an inclusive workplace where every employee, whether part-time, full-time, or temporary, or employed through our business partners, is treated with dignity and respect.

Our Commitment

• Non-Discrimination: We reject all forms of unlawful and unfair discrimination. We are committed to creating an environment free from discrimination, where every individual is valued for their unique contributions.
• Equal Treatment: In all aspects of employment, including selection for employment, promotion, training, and other benefits, we will base our decisions solely on aptitude and ability, ensuring fairness and impartiality.
• Development and Maximisation of Potential: We are dedicated to helping all our employees reach their full potential. By harnessing the talents and resources of our diverse workforce, we aim to enhance our organisation’s efficiency.

Our Pledge

• Respectful Working Environment: Every employee at Left Field is entitled to a working environment that upholds dignity and respect for all. We have a zero-tolerance policy for any form of intimidation, bullying, or harassment.
• Business Sense: Our commitment to diversity and equality is not just a moral stance; it is also a cornerstone of good management practice that enhances our business performance.
• Disciplinary Consequences: Violations of our diversity and equality policy will be considered misconduct and may result in disciplinary proceedings.
• Senior Management Support: This policy is fully endorsed and supported by our senior management team.
• Continuous Review: We will regularly monitor and review this policy to ensure its effectiveness and relevance in our evolving workplace.

Implementation

The Equality and Diversity statement embodies Left Field’s commitment to creating a fairer society by “removing the barriers that limit what people can do and can be.” We will actively promote this statement within our organisation and work towards its realisation.

At Left Field, we recognise that diversity and equality are essential to our success. We are dedicated to fostering an inclusive workplace where all individuals have the opportunity to thrive, and we invite all our employees to join us in this commitment.

Date of Last Revision:  June 2024

1. Purpose

The aim of this policy is to implement controls ensuring adherence to all relevant anti-bribery and corruption laws, and to guarantee that the Company’s operations are conducted with social responsibility.

2. Policy Statement

Bribery involves offering, promising, giving, accepting, or soliciting an advantage as an inducement for illegal action or breach of trust. A bribe is an incentive or reward offered to gain any commercial, contractual, regulatory, or personal benefit.

Our policy mandates conducting all business honestly and ethically. We adopt a zero-tolerance stance towards bribery and corruption, committing to professional, fair, and integrity-driven business dealings worldwide. We enforce robust systems to counter bribery.

We adhere to all laws related to countering bribery and corruption in every jurisdiction we operate in, while being bound by the UK Bribery Act 2010 globally.

Bribery and corruption can lead to severe consequences, including imprisonment and fines for individuals, and unlimited fines, exclusion from public tenders, and reputational damage for the Company. Therefore, we take our legal responsibilities very seriously.

3. Scope

3.1 Who is Covered by the Policy?

In this policy, “third party” means any individual or organisation you interact with during your work for us, including actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives, politicians, and political parties.

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, extended-term, or temporary), consultants, contractors, trainees, seconded staff, home workers, casual workers, and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy). This policy covers:

• Bribes
• Gifts and hospitality
• Facilitation payments
• Political contributions
• Charitable contributions

3.2 Bribes

Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world.

3.3 Gifts and Hospitality

Employees must not offer or give any gift or hospitality:

• Which could be regarded as illegal or improper, or which violates the recipient’s policies; or
• To any public employee or government officials or representatives, or politicians or political parties.

Employees may not accept any gift or hospitality from our business partners if:

• There is any suggestion that a return favour will be expected or implied.
• Where a manager’s approval is required above, if the manager is below Director level, then approval must be sought from an appropriate Director.
• If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the employee’s manager and donated to charity.

We appreciate 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. The intention behind the gift should always be considered.

Within these parameters, local management may define specific guidelines and policies to reflect local professional and industry standards. Where this policy requires written approval to be given, the Company Secretary shall put in place a process to maintain a register of all such approvals.

3.4 Facilitation Payments and Kickbacks

Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low-level officials to obtain a level of service which one would normally be entitled to.

Our strict policy is that facilitation payments must not be paid. We recognise, however, that our employees may be faced with situations where there is a risk to the personal security of an employee or their family and where a facilitation payment is unavoidable, in which case the following steps must be taken:

• Keep any amount to the minimum
• Create a record concerning the payment
• Report it to your line manager

To achieve our aim of not making any facilitation payments, each business of the Company will keep a record of all payments made, which must be reported to the Company Secretary/Accounts department, to evaluate the business risk and to develop a strategy to minimise such payments in the future.

3.5 Political Contributions

We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.

3.6 Charitable Contributions

Charitable support and donations are acceptable (and indeed are encouraged), whether of in-kind services, knowledge, time, or direct financial contributions. However, employees must ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the compliance manager. All charitable contributions should be publicly disclosed.

4. Your Responsibilities

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

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 employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager or the Company Secretary or the confidential helpline as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.

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.

5. Record-Keeping

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

You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

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.

All accounts, invoices, memoranda, and other documents and records relating to dealings with third parties, such as clients, 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.

6. 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 or concerns, these should be raised with your line manager or the Company Secretary or through the confidential helpline.

7. What to Do if You Are a Victim of Bribery or Corruption

It is important that you inform the Company Secretary, Company head office, Accounts Department, or the confidential helpline 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.

8. Protection

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, may sometimes worry 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.

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 compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the company’s Grievance Procedure.

9. Training and Communication

Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to formally accept conformance to this policy on an annual basis.

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.

10. Who Is Responsible for the Policy?

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. The Company Secretary 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. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.

11. Monitoring and Review

The Company Secretary 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. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries should be addressed to the Company Secretary. This policy does not form part of any employee’s contract of employment and it may be amended at any time.

Reviewed: June 2024