Corporate Governance & Compliance

1. Policy statement

Aprirose Trading Limited 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 Aprirose Trading Limited’s behalf is responsible for maintaining its reputation and for conducting company business honestly and professionally.

Aprirose takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever it operates.

The statement sets out responsibilities, provides guidance on recognising and dealing with bribery and corruption, and explains how concerns or breaches should be raised.

2. What is bribery?

A bribe is broadly an inducement or reward offered, requested, promised or provided to gain a commercial, contractual, regulatory or personal advantage. The policy also addresses the offence of offering a bribe to a foreign public official to obtain or retain business or an advantage where local law does not permit it.

3. Responsibilities

Prevention, detection and reporting are the responsibility of those working for Aprirose, supplying services to it, or under its control.

4. Gifts and hospitality

Normal and appropriate corporate entertainment, gifts, hospitality and promotional expenditure may be permitted when undertaken in good faith for legitimate business purposes and not to secure an improper advantage or influence impartiality.

The policy sets an approximate £50 threshold for gifts and hospitality without prior approval. Cash gifts must never be accepted or offered. The reasonableness, justification and intention behind every gift or instance of hospitality must be considered.

5. What is not acceptable?

• Offering or accepting payments, gifts or hospitality with an expectation of business advantage.
• Offering improper payments to government officials or foreign public officials.
• Threatening or retaliating against someone who refuses to commit bribery or raises a concern.
• Engaging in activity that could lead to a breach of the policy.

6. Facilitation payments and kickbacks

Aprirose and its service providers must not make or accept facilitation payments or kickbacks. Payments made on Aprirose’s behalf should be proportionate to the goods or services provided, supported by a receipt, and accurately recorded in contracts and documentation.

7. Record keeping

Financial records and appropriate internal controls should evidence the business reason for payments given to or received from third parties.

8. Raising concerns

Suspected breaches should be reported to Aprirose Trading Limited Director Parag Gudka at parag@aprirose.com.

1. General statement

Aprirose states that it will maintain a high level of commitment to good environmental policy throughout its business activities, minimise waste through good purchasing practice, and reuse or recycle materials whenever practical.

Systems and procedures are intended to encourage recycling and reduce overall waste. Staff are expected to follow the procedures and support management in carrying out the policy.

2. Specific aims

• Build awareness of waste management, waste minimisation, reuse and recycling.
• Promote economy in the use of materials, particularly plastic and paper.
• Prefer recycled, reclaimed and sustainably sourced materials suited to recycling.
• Favour suppliers that actively apply sound environmental principles.
• Encourage exchange and reuse of equipment and materials across departments and sites.
• Develop recycling procedures and schemes relevant to each activity.

3. Future recycling

Aprirose states that it intends to expand recycling procedures, including the potential recovery and recycling of plastic waste.

4. Environmental statement

The policy commits Aprirose to evaluating environmental impacts, defining objectives and improvement actions, providing relevant training, communicating performance, preparing for environmental emergencies, and reviewing the policy as legislation and best practice change.

Signed on the current website by Parag Gudka, Director.

• Minimise the use of energy, water and natural resources.
• Minimise waste through prevention, reuse and recycling where possible.
• Dispose of waste safely and legally.
• Avoid hazardous materials where practical.
• Work with environmentally responsible suppliers.
• Prevent environmental damage and minimise nuisance such as noise and air pollution.

Purpose

The Sustainability Policy aims to reduce, mitigate and manage sustainability risks and impacts, and to create environmental, economic and social value through education, awareness, community investment, people development, strategic alliances and business opportunities that support climate, ecosystem and circular-economy objectives.

Focus areas

• Conducting business responsibly through governance processes.
• Contributing to a more just, equal and inclusive society.
• Protecting the environment for people, ecosystems and climate.
• Enabling a more circular economy.

Governance, ethics and compliance

The policy describes stakeholder engagement across diverse cultures and markets and an ethical approach covering data privacy, anti-corruption, transparency, regulatory compliance and risk management.

• Maintain high standards of integrity and corporate governance.
• Measure and report sustainability performance.
• Assess and mitigate environmental, social and governance risks and impacts.
• Integrate sustainability considerations into financial and non-financial decision-making.

Human rights and worker welfare

Aprirose states that it is committed to health, safety and human rights in its operations and third-party relationships, with reference to international standards including the UN Guiding Principles, UN Global Compact, Universal Declaration of Human Rights, ILO core conventions and the Voluntary Principles on Security and Human Rights.

• Non-discrimination and freedom from harassment.
• Prohibition of child labour, forced labour, human trafficking and modern slavery.
• Freedom of association, health and welfare, and a safe and secure working environment.

Environment and circular economy

Employees are expected to reduce waste, water and energy footprints where possible. The policy also describes applying Aprirose’s knowledge and logistics to circular value chains, supporting circular products and building awareness among customers, suppliers, communities and families.