1. Introduction

It is the policy of BANDAI NAMCO Entertainment UK Ltd (BNE UK) to conduct business in a
fair, honest and transparent way and not to use corrupt practices or acts of bribery to
obtain an unfair business advantage. BNE UK is committed to ensuring adherence to
the highest ethical and legal standards and to bringing integrity to every aspect of its
business activities, in line with the BANDAI NAMCO Group’s Declaration of

This policy has been adopted by the BNE UK Board and is to be communicated to
everyone involved in our business to ensure their commitment to it. The Board
attaches the utmost importance to this policy and will apply a “zero tolerance”
approach to acts of bribery and corruption by any of our employees or business
partners working on our behalf which contravene the Bribery Act 2010. BNE UK
will treat any breach of this policy as a serious matter which is likely to result in
disciplinary and/or legal action.

2. Policy

BNE UK prohibits the offering, giving, demanding or receiving of any bribe whether
in the form of cash or any other inducement:


  • to or from any person or company, whether a public official or body, or a private person or company wherever situated
  • by any individual employee, agent or other person or company acting on behalf of BNE UK
  • in order to gain any commercial, contractual or regulatory advantage for BNE UK in a way which is unethical
  • or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

3. Gifts and Corporate Hospitality

Gifts and corporate hospitality include the offering or acceptance of gifts, meals or
tokens of appreciation and gratitude, invitations to events, functions or other social
gatherings. As long as they fall within reasonable bounds in terms of value and
occurrence, the following activities are allowable:


  • gifts may be offered at festive occasions, eg Christmas, as part of the overall account management process provided that they are appropriate to the scale of the business relationship between the recipient and BNE UK and are approved beforehand by the MD.
  • similar festive gifts may be accepted by BNE UK staff provided that they are appropriate to the scale of the business relationship between the donor and BNE UK and are notified to either the MD or the FD.
  • the provision of any form of corporate hospitality as outlined above must be transparent and always be approved beforehand by the MD.
  • The acceptance of any similar form of corporate hospitality by BNE UK staff must be notified either to the MD or the FD beforehand for their approval.

For the avoidance of doubt:


  • the provision or acceptance of gifts or corporate hospitality during the tendering or procurement process is prohibited.
  • no facilitation payments to foreign officials for securing or accelerating routine processes or procedures are allowed, regardless of amount.
  • normal expenses incurred on business travel, accommodation and meals are exempt provided that they are in line with the company’s Expenses Policy and are properly approved.

4. Employee Responsibility

The prevention, detection and reporting of bribery is the responsibility of all BNE UK employees. If and when any instance of bribery is identified, the incident or suspected incident of bribery must be reported immediately in accordance with the company’s “Whistle Blowing” policy, which provides details of who to contact with any concerns or doubts as to whether a potential act constitutes bribery. (Refer to the HR policy section 12 as for the code of conduct since we have no whistle blowing
process in place)

Managers must ensure that all employees are aware of this policy and of their responsibilities to act accordingly.

5. Communication

In order for this Code of Conduct and Anti-Bribery Policy to be communicated effectively to everyone involved in BNE UK’s business and to ensure compliance, they will be:


  • E-mail to all employees when initiated for the first time.
  • Anti-Bribery Policy and Code of Conduct to be given to all new starters.