Immersive Experiences Modern Slavery Policy

Updated January 2023

This modern slavery and human trafficking policy is aligned with our Ethical Principles. All those to whom this policy applies are encouraged to familiarise themselves with them. If you have any queries about this policy please contact your line manager.

Policy

Immersive Experiences (the “Company”) has a comprehensive set of principles, structures, policies and procedures demonstrating the ethical standards that the Company sets across all of its activities.
The Company expects all its staff and students to follow the ethical behaviours set out in the Nolan Principles: selflessness, integrity, objectivity, accountability, openness, honesty and leadership. These Principles are incorporated into this policy and underlie the Company’s Ethical Framework.
The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with controls to take steps to ensure modern slavery is not taking place anywhere in its own business or in any of its supply chains.
The Company is also committed to taking steps to ensure there is transparency throughout its business, in line with its obligations under the Modern Slavery Act 2015. The Company expects the same high standards from all its contractors, suppliers and other business partners. We also expect that our suppliers will hold their suppliers to the same high standards.

Scope of Policy

This policy applies to all persons working for the Company or on its behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and the Company may amend it at any time.
Management at all levels is responsible for ensuring those reporting to them are made aware of this policy and attend the relevant training.

Compliance

You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is 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.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at any level of supply at the earliest possible stage, or if you suspect a breach of this policy has occurred or may occur. You must notify your line manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
If you are unsure of any aspect of a supplier’s activities with regard to this policy, raise it with your line manager.
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 reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. 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 your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally.

Communication

Appropriate training on the business risks from modern slavery in its supply chains will be provided as necessary.
Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners throughout our business relationship with them.

Breaches

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Immersive Experiences Anti-Bribery Policy

1.1 Immersive Experiences (the “Company”) has a zero-tolerance policy towards bribery and corruption of any kind and is committed to carrying out its business functions in a fair, honest, ethical and open manner. This policy applies to all our dealings, anywhere in the world, with both public officials and those in the private sector.

In essence, our policy for all staff and contractors is simple:

Do not offer, promise, or pay bribes
Do not request, agree to, or accept bribes

whether this be money, gifts, hospitality or any other payment, advantage, or favour.

Our staff adhere to the following principles:

Do not offer any money, gift, hospitality or other payment or advantage to someone (or favour them in any other way) if you know that this will put someone in a difficult situation, or with the intention of influencing them for business purposes.
Do not misuse your position (or perform your functions improperly) in connection with any money, gift, hospitality or other payment or advantage (or other favours) for yourself or others.

Purpose

The purpose of this policy is to:

Set out the Company’s responsibilities in observing and upholding our position on bribery and corruption;
Provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues;
Set out the Company’s processes on the receipt or giving of gifts and hospitality;
Ensure that the Company complies with anti-bribery regulations.

The Board has global responsibility for this policy and for dealing with any queries in relation to it. For the purposes of the Bribery Act, the CEO is the Company’s Bribery Act compliance officer.

Management at all levels within the Company are responsible for promoting this policy and ensuring those reporting to them are made aware of and understand this policy. All employees, contractors and persons related to the company are covered by this policy.

Definition

A bribe does not need to be a monetary sum. It can be any form of improper inducement or reward offered, promised or provided in order to gain (or to reward) any commercial, contractual, regulatory or personal advantage.

A recipient of a bribe does not need to benefit personally, and actual payment of a bribe does not need to occur for there to be a criminal offence. An offer or request would be sufficient.

A person can be guilty of giving or receiving a bribe under the Bribery Act if there was an intention to induce or reward “improper performance” of a function or activity through offering, promising or paying a bribe. What is proper or improper is judged objectively. It is no defence to rely, for example, on local customs or norms as justification for making a payment that would otherwise be considered a bribe.

Sometimes offering or making a payment (or performing some other favour) can be a Bribery Act offence – where the payment or favour is in itself improper. The recipient does not necessarily need to do anything else as a consequence.

The Bribery Act also contains a separate offence of bribing a foreign public official; as well as an offence that can be committed by organisations of failing to prevent bribery by any person performing services for or on behalf of the organisation.

Issues

Engaging in bribery practices can lead to severe personal penalties, but also serious sanctions for the Company as well. This will go on to have consequences for the ongoing running of the business.

Under the Bribery Act, a gift, hospitality or entertainment need only be given to a Foreign Public Official with the intention of influencing the official in his/her capacity in return for business to be considered bribery.

The definition of Foreign Public Official includes a wide range of people who have influence over the conduct of state institutions or the management of state assets and institutions.

The Company does not make contributions to political parties. The Company supports charitable giving and initiatives by colleagues, however, it is only open to the Company to make charitable donations at an institutional level in limited prescribed circumstances.

Gifts and Hospitality

This policy does not prohibit modest gifts and reasonable hospitality (given and received) to or from third parties provided certain rules and requirements are met.

All staff should adhere strictly to the following two anti-bribery rules in respect of gifts, hospitality and entertainment:

Never offer, promise or give a gift, hospitality or entertainment where this may be construed as a bribe or be otherwise improper.
Never request, agree to or accept a gift, hospitality or entertainment where this may be construed as a bribe or be otherwise improper.

Gifts, hospitality and entertainment (whether given or received), must:

Be approved in advance, if it falls outside certain limits.

- Have a genuine and legitimate purpose, such as the promotion of the Company’s services or to establish cordial relationships with those with whom we work;
- Not risk being perceived as lavish or excessive;
- Comply with all applicable local laws as well as the Bribery Act (if given or received outside of the UK) and comply with any other rules relevant to the recipient (such as their own organisation’s policies in this area);
- Not be offered or received at an inappropriate time (such as during a competitive tender involving the recipient or in advance of another business decision the recipient is involved with), which might risk being perceived as improperly influencing the recipient;
- Never include cash or a cash equivalent, such as gift certificates or vouchers; and
- Be given openly, not secretly; and be correctly and transparently documented in the Company’s accounting and other written records.

Gifts include any token of appreciation and gratitude, gift vouchers, cash, physical gifts or other items of value, whether offered, given or received.

Hospitality and entertainment can include any attendance at social events, conferences, functions, or other occasions, business lunches or drinks and any travel or accommodation provided in connection with the hospitality and entertainment.

For gifts, hospitality and entertainment staff need to obtain prior approval for accepting or offering gifts, hospitality and entertainment of a certain level or involving particular categories of recipient.

- For Gifts (given or received) approval is required in all cases except:
  - In the UK, no approval is required for offering any gift under £50 or accepting a gift under £140, or for symbolic gifts/corporate memorabilia of low financial value. It is only likely to be appropriate to receive a low value corporate memorabilia level gift from a supplier or potential supplier.
- For Hospitality and Entertainment (given or received) approval is required in all cases except:
  - In the UK, no approval is required for any hospitality under £50 per person entertained.
  - In all other jurisdictions, there are no exceptions to the requirement for approval.
  - It is unlikely to be reasonable to accept regular or frequent corporate hospitality, particularly from the same source.

Where a gift prohibited by this policy is offered to or received by a person working for the Company it should be refused. The Company recognises that in certain circumstances it can be considered impolite to refuse a gift from a third party. Therefore it is important that gifts prohibited by this policy be refused in such a way as to avoid causing any offence. In some countries it may be common for a recipient to politely refuse a gift, sometimes repeatedly and it is also generally expected that the giver will persist and the recipient will eventually accept. Where a gift is offered or given contrary to this policy, however, the gift should nevertheless be refused in a manner sensitive to all the circumstances.

This may entail thanking the giver for their thoughtfulness taking care not to embarrass them, and expressing your apologies for not accepting the gift and explaining why, mentioning the Company’s policy and specific rules as necessary.

If the gift has already been received and the giver refuses to take it back, the gift should be handed to your line manager within the Company who should report the matter to the CEO.

All gifts offered or received, and details of their refusal should be declared.

Responsibilities

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for or associated with the Company. You are required to avoid any activity that risks a breach of this policy.

Effective risk assessment in order to evaluate and mitigate risk is an essential element of this policy. Colleagues must assess the vulnerability of their activities, particularly overseas, on an ongoing basis.

You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. This includes notification of any demand for a facilitation payment.

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

Where payments are made to third parties, the legitimate business reason for such payments must always be clearly recorded and submitted.

You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your line manager in the first instance. If you or your line manager require further guidance, you should contact the CEO.

Protections

It is important that you tell your line manager 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. Any concerns about bribery or attempted bribery, or fears of repercussions for not taking a bribe, should also be reported promptly to your line manager or directly to the CEO.