Anti-Bribery and Corruption Policy 

At Sonan Bunkers,  we value transparency, quality and integrity in all transactions. We believe that running a business responsibly is about supplying excellent products without compromising the environment, our integrity / the integrity of others, and/or engaging in any corrupt or dishonest behaviours.

All SONAN employees, stakeholders and suppliers are expected to uphold anti-bribery and anti-corruption policies at all times.

SONAN BUNKERS takes a zero-tolerance approach to both crimes and acts proactively and quickly to prevent their occurrence.



The Bribery Act 2010 makes it an offence to offer, promise or give a bribe. It is also an offence to request, agree to receive or accept a bribe. The Company has a zero-tolerance approach to bribery and corruption and sets out below the general rules and principles to which the Company adheres and with which all employees must comply. 

The Anti-Bribery and Corruption Policy and associated documents will be issued to you separately on an annual basis. It is a condition of your continued employment that you sign an annual declaration that you agree to be bound by its contents.

Disciplinary action We are committed to this policy and take a zero-tolerance approach to any act of bribery or corruption by a member of staff. Any employee found to have offered or accepted a bribe will face disciplinary action up to and including summary dismissal for gross misconduct. 

Raising concerns If an employee is concerned that acts of bribery are occurring in the organisation they should inform their manager in the first instance. If this course of action is inappropriate, the employee should inform a Director. 

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

What is bribery and corruption? Bribery is the offer, promise, giving, demanding or acceptance of an advantage as an inducement for an action that is illegal, unethical or a breach of trust. 

Corruption is the misuse of public office or power for private gain or misuse of private power in relation to business outside the realm of government. 

Acts of bribery or corruption are designed to influence the individual in the performance of their duty and incline them to act dishonestly. For the purposes of this policy, whether the payee or recipient of the act of bribery or corruption works in the public or private sector is irrelevant. 

The person being bribed is generally someone who will be able to obtain, retain or direct business. This may involve sales initiatives, such as tendering and contracting; or, it may simply involve the handling of administrative tasks. It does not matter whether the act of bribery is committed before or after the tendering of a contract or the completion of administrative tasks. 

What is a bribe? Bribes can take on many different shapes and forms, but typically they involve corrupt intent. There will usually be a 'quid pro quo' - both parties will or are expected to benefit. A bribe could be: 

  • the direct or indirect promise, offering, or authorisation, of anything of significant value; 
  • the offer or receipt of (or agreement to receive) any kickback, loan, fee, reward or other advantage; or 
  • the giving of aid, donations or voting designed to exert improper influence. 

There need not be an immediate benefit: an expectation of a later benefit will make it a bribe. 

A third-party benefit will also constitute a bribe. A third party is 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, advisers, joint venture partners, consultants and government and public bodies, including their advisors, representatives and officials, politicians and political parties. It does not include existing competitive co-broking channels where the co-broker is known to us. 

Therefore, bribes are not limited to cash payments. Job offers, gifts and entertainment, excessive business promotional activities, covering or reimbursing expenses, in-kind or political contributions, investment opportunities, subcontracts, stock options and similar items provided to third parties are all things of value that can contravene the applicable legislation.

Who can engage in bribery or corruption? In the eyes of the law, bribery and corrupt behaviour can be committed by: 

  • an employee, officer or director; 
  • any person acting on behalf of the Company (i.e. third-party representatives); and 
  • individuals and organisations where they authorise someone else to carry out these acts. 

Acts of bribery and corruption may (but will not always as it can be anyone connected to the business), involve public or government officials. For the purposes of this policy, a government official could be: (i) a public official, whether foreign or domestic; (ii) a political candidate or party official; (iii) a representative of a government- owned/majority-controlled organisation; or (iv) an employee of a public international organisation. 

Please note, there is no distinction between commercial parties and public or foreign officials and this policy prohibits bribes of any kind to anyone, whether they are employed by a commercial business or considered a public or foreign official. As a general guiding principle, you must not offer anything to, or receive anything from, third parties, whether or not you consider them to be foreign officials and whether directly or indirectly, in return for or in the expectation of favourable treatment. 

Detailed procedures You should never give or offer bribes to further the Company's business nor should you accept or agree to accept bribes to further the Company's business. 

In order to demonstrate to the relevant authorities that the Company does not engage in the giving or acceptance of bribes it must keep accurate records.  The records will be monitored on a regular and on-going basis to ensure that the Anti-Bribery & Corruption Policy is being adhered to. 

You must be alert to attempts to influence you inappropriately or to engage in/facilitate bribery. This is especially relevant to those procuring goods or services or dealing with third parties on our behalf. 

You must not accept any inducement designed to influence you inappropriately in the performance of your job. 

Do not accept gifts from customers, suppliers, any other person or organisation with whom we do (or might develop) business. This avoids any misunderstandings or allegations of impropriety. It is important you do not act inconsistently with our standards or, however inadvertently, impugn our integrity. Accepting a gift which influences or seems to influence your actions or decisions on our behalf may do this. 

You must not accept money, gifts or other rewards from clients, suppliers etc contrary to our normal practices. Do not accept inappropriate levels of hospitality. Accepting lunch may be acceptable. Accepting a free holiday will not. If unsure, check first with your line manager. 

You may accept small, genuine tokens of appreciation or gratitude which are commensurate with common practice in our organisation. They must be proportionate and reasonable and you must declare them. You must not treat the person/organisation that provides such gift more favourably than other clients/suppliers, etc. If unsure, check first with your manager. 

Where you are unsure or feel refusal of a gift or hospitality might cause difficulty, consult your manager first. This policy does not apply to promotional items such as stationery or pens with a logo or company name. This is always provided the items have no significant value. 

Third party representatives The definition of a third-party is broad. Whilst the use of third-parties can help us reach our goals, we need to be aware that these arrangements can potentially present the Company with significant risks. It does not include existing competitive co-broking channels. 

To assist us in identifying the risk where a third-party conducts business activities on the Company's behalf, the effect of which is that the result of their actions have benefited the Company. Third- parties who pose significant risks and act on the Company's behalf must operate at all times in accordance with the Company's Anti- Bribery & Corruption policy. 

The Third Party Evaluation Form must be completed for each new third party representative used including new co-broking channels. The form must be signed by the broker who has the relationship and approved by the Head of Department. A scanned copy of the completed form must sent to the Compliance Officer and the original kept by the department. 

Once the Third Party Evaluation Form has been authorised the broker must send the Third Party Declaration Form together with a copy of the Anti-Bribery & Corruption Policy to the third party. The original of the signed form must be kept by the department and a scanned copy sent to the Compliance Officer. 

Conclusion It is the ultimate responsibility of the main Board routinely to refresh and reinforce this policy and its underlying principles and guidelines. 

All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. The Head of Department is responsible for the establishment and ongoing monitoring of this policy. 

Worldwide Offices

Ground Floor,
10 Coldbath Square
United Kingdom

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Vouliagmenis Ave 84
& V. Georgiou 17,
Voula 166 73,

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World Trade Center,
Beursplein 37, 3011 AA,
3rd floor, Room 3.03

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Grundingen 6,

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Rio de Janeiro
Rua da Quitanda
52 -1002,
CEP 20.011-030 Centro

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16 Raffels Quay
Hong Leong Building

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JLT Cluster 1
Platinum Tower
Jumeirah Lake Towers
United Arab Emirates

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H.P. Hansens Plads 32

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