Anti-Bribery Statement

Our commitment to preventing bribery

Focus International Limited T/A Focus Brands (“we/us/ the Company”) is committed to applying the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. Every employee and individual acting on our behalf is responsible for maintaining our reputation and acting honestly and professionally.

We consider that bribery and corruption have a detrimental impact on business by undermining good governance and distorting free markets.

We benefit from carrying out business in a transparent and ethical way and helping to ensure that there is honest, open and fair competition in our industry. Where there is a level playing field, we lead the market in design, sourcing, distribution, and promotion for sports fashion, understanding the unique needs of the fashion and lifestyle industry.

Transparent, fair conduct helps to foster deeper relationships of trust between our organisation and its business partners and customers. It is vital for our reputation and future growth.

We do not tolerate any form of bribery, whether direct or indirect, by, or of, its employees, officers, agents or consultants or any persons or companies acting for it or on its behalf. The board and senior management are committed to implementing and enforcing effective systems throughout our organisation to prevent, monitor and eliminate bribery, in accordance with the Bribery Act 2010.

Anti-bribery policy

We provide an anti-bribery policy outlining our position on preventing and prohibiting bribery on the staff intranet. The anti-bribery policy applies to all employees, as well as agency workers, consultants, and contractors. All employees and other individuals acting for our organisation are required to familiarise themselves and comply with our anti-bribery policy.

A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Employees and others acting for or on behalf of our organisation are strictly prohibited from making, soliciting, or receiving any bribes or unauthorised payments.

As part of its anti-bribery measures, we are committed to transparent, proportionate, reasonable, and bona fide hospitality and promotional expenditure. Such expenditure must be authorised in advance, in accordance with the procedures set out in our anti-bribery policy.

Breaches of our anti-bribery policy

A breach of our anti-bribery policy by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct, and immediate dismissal. Employees and other individuals acting for Focus Brands should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for our company.

We will not conduct business with service providers, agents or representatives that do not support our anti-bribery objectives. We reserve the right to terminate its contractual arrangements with any third parties acting for, or on behalf of, our organisation with immediate effect where there is evidence that they have committed acts of bribery.

The success of our anti-bribery measures depends on all employees, and those acting for us, playing their part in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on behalf of, our company are encouraged to report any suspected bribery in accordance with the procedures set out in the anti-bribery policy. We will support any individuals who make such a report, provided that it is made in good faith.