Policy Statement

• Duckworth & Kent Ltd. (D&K) conducts its business in an honest and ethical manner.
• D&K upholds all laws relevant to the U. K. Fraud Act (2006) and the Bribery Act (2010).
• D&K is committed to acting professionally, fairly and with integrity in all its business dealings and relationships.
• Every employee acting on D&K’s behalf is responsible for maintaining its reputation.
• D&K takes a zero tolerance approach to fraud and bribery, a form of corruption which is illegal.
• D&K implements and enforces effective systems to counter fraud and bribery.
• D&K keeps appropriate financial records and internal controls which evidence the business reason for gifts, hospitality and payments made and received.

Fraud

• Fraud can be committed through false representation, by failing to disclose information or by abuse of position.
• Actions which fall within the definition of fraud include: theft of company property; use of company assets for personal gain; false accounting; forgery or alteration of company documents; wilful destruction of company records; computer-related activity associated with the above; knowingly generating false claims; unauthorised disclosure of confidential information.

Bribery

• A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage.
• This can be in the context of giving or receiving.
• In practical terms, a financial or other advantage is likely to include cash or cash equivalents, gifts, meals, services, loans, or preferential treatment.
• An offence is committed when the bribe is coupled with an intention of inducing a reward for, or in anticipation for a person to improperly perform their function.

Corruption

• Corruption is the misuse of power for private gain.

D&K’s Responsibilities

• The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of everyone working for D&K. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
• Employees are required to notify the Chairman of D&K as soon as possible if it is believed or suspected that a conflict with this policy has occurred or may occur in the future.
• Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct.
• D&K reserves a right to terminate a contractual relationship with non­employee workers if they breach this policy.
• If anyone has any questions or concerns about D&K’s anti-bribery and corruption policy, then please contact the Chairman of D&K (andrewwaldock@duckworth-and-kent.co.uk).

Gifts and Hospitality

• D&K permits normal and appropriate corporate entertainment, gifts, hospitality and promotional expenditure (given and received) to or from third parties that is undertaken for the purpose of establishing and maintaining good business relationships.
• D&K permits the above provided that it is given in good faith and not offered, promised or accepted to secure an advantage, or influence the impartiality of the recipient.
• D&K does not make, and will not accept, facilitation payments or ‘kickbacks’ of any kind. Any transactions in contracts must be recorded so that there is never any attempt to hide the way a contract will work.

Duckworth & Kent Ltd has a policy to conduct its business in a manner that is compatible with the balanced environmental and economic needs of the community. The Company is committed to continuous efforts to improve environmental performance throughout its operations.

Accordingly, the Company’s policy is to:

• Comply with all applicable environmental laws and regulations and apply responsible standards where laws and regulations do not exist.
• Encourage concern and respect for the environment, emphasise every employee’s responsibility in environmental performance, and foster appropriate operating practices and training.
• Manage its business with the goal of preventing incidents and of controlling any emissions and waste to below harmful levels; design, operate and maintain facilities and processes to this end.
• Respond quickly and effectively to incidents resulting from its operations, in co­operation with industry organisations and authorised government agencies.
• To improve methods of environmental protection and to enhance its capability to make operations and products compatible with the environment.
• Communicate openly on environmental matters and share its experience with others to facilitate improvements in overall industry performance.
• Undertake appropriate reviews and evaluations of its operations to measure progress and to foster compliance with this policy.

Commitment to equality of opportunity in employment.

Duckworth & Kent Ltd. recognises the benefits of a diverse workforce and is committed to providing a working environment that is free from discrimination.

The Company seeks to promote the principles of equality and diversity in all its dealings with employees, workers, job applicants, clients, customers, suppliers, contractors, recruitment agencies and the public.

All employees and those who act on the Company’s behalf are required to adhere to this policy when undertaking their duties, or when representing the Company in any other guise.

Unlawful discrimination of any kind in the working environment will not be tolerated and the Company will take all necessary action to prevent its occurrence.

Specifically, the Company aims to ensure that no employee or job applicant is subject to unlawful discrimination, either directly or indirectly, on the grounds of gender, gender reassignment, race (including colour, nationality, caste and ethnic origin), disability, sexual orientation, marital status, part-time status, pregnancy or maternity, age, religion or belief, political belief or affiliation or trade union membership.

This commitment applies to all aspects of employment.

Duckworth & Kent Ltd is a market leader in the sustainable quality design, manufacture and supply of reusable, titanium, precision engineered ophthalmic instruments.

It is our aim to:

• Provide Quality products that have been designed and manufactured in-house to exceptionally high standards of engineering excellence, thus ensuring repeatable performance and reliability in their use, meeting our customers’ requirements and expectations.
• Partner with our customers to deliver a seamless and transparent experience before, during and after a purchase.
• Create Value for our customers through a safe, high performing workplace utilising quality equipment and processes efficiently and sustainably.
• Empower a dedicated, trained and competent workforce.

For this reason, we have implemented a formal, documented Business Management System structured to meet the requirements of ISO13485:2016 and EC 93/42/EEC as amended, which is certified by an accredited third party assessment organisation.