ANTI-CORRUPTION AND BRIBERY POLICY
Pathe Productions Limited (hereinafter, the Company) understands that the Company’s success and reputation are
based not only on the quality and innovation of its work but also on the trust placed in it by its customers, suppliers,
sub-contractors, distributors, agents, partners and employees. To ensure this, the Company follows certain essential
values: integrity, transparency, loyalty, respect, compliance with the law and an expectation of professionalism. These
key values are the foundation for the behaviour of employees, officers and directors of the Company (together
hereinafter referred to as Employees) and are also expected to be followed by those working with and for the Company
and on the Company’s productions.
The Company has an internal Code of Conduct for Employees which sets out the Company’s policies (including those
referred to below) and the corresponding responsibilities of Company’s Employees. The Company’s Code of Conduct
and procedures are reviewed on a regular basis.
1. Anti-Corruption & Influence Peddling
1.1 It is the Company’s policy (Anti-Corruption Policy) to comply fully with the anti-corruption laws of the United
Kingdom (including without limitation, the Bribery Act 2010, as amended from time to time [Bribery Act]), of France
(including without limitation French Law No. 2016-1691 of 9 December 2016, commonly referred to as “Sapin 2”
[Sapin 2]) and the United States of America (including, without limitation, the U.S. Foreign Corrupt Practices Act, 15
U.S.C. Section 78dd-1 and 78dd-2, as amended from time to time [FCPA]), and any other applicable anti-corruption
laws and legislation anywhere in the world (collectively and individually, the Anti-Corruption Legislation).
1.2 The Company’s Anti-Corruption Policy also includes a prohibition against so-called “influence peddling” (the
misuse of real or supposed influence in order to obtain any undue benefit, usually from a public authority).
1.3 The Company takes a zero-tolerance approach to bribery, corruption and influence peddling and is
committed to acting professionally, fairly and with integrity in all Company’s business dealings and relationships
wherever Company operates throughout the world.
1.4 The Company expects that those parties engaged to work with, or for, the Company on any of the Company’s
productions will comply with the Company’s Anti-Corruption Policy and such third parties are made aware of the
Company’s policies (including the Company’s Anti-Corruption Policy). The Company also prohibits the hiring and use
of the services of intermediaries or agents that are likely to carry out or incite acts of corruption and/or influence
1.5 The Company monitors Transparency International’s “Annual Corruption Perceptions Index” and exercises
special care when doing business or engaging in activity in so-called “high-risk countries”.
1.6 The Company expects that all contracts and transactions with and on behalf of the Company must comply
with all applicable law(s) and that all payments made under such contracts should be traceable (and should not be
made in cash unless exceptional circumstances apply). All payment terms in contracts must be transparent and have
clear commercial justification, with fair and proportionate benefits for all parties with the basis for any calculations
and/or allocations clearly set out.
1.7 The Company also follows the “Anti-Bribery High Level Principles & Guidelines for Independent Producers”
collated by Pact with support from the BBC, ITV, Channel 4 and Channel 5 as best practice in seeking to ensure
compliance with the Bribery Act when working on the Company’s production activities.
2. Gifts & Invitations
2.1 As part of the Company’s Anti-Corruption Policy, the Company also has a Gifts and Invitations Policy to ensure
that any gifts and/or invitations are (and must be) given or received openly and in good faith and of a reasonable value
taking into account the circumstances, consistent with applicable practices in the United Kingdom film and television
industry and compliant with all statutes and regulations in force,
2.2 The Company does not make, and will not accept, so-called facilitation payments or "kickbacks" of any kind.
3. Tax Evasion
The Company shall not engage in any activity, practice or conduct which could constitute tax evasion
(whether in the UK or in any other jurisdiction) and shall comply fully with all applicable tax anti avoidance laws,
including those under Part 3 of the Criminal Finances Act 2017 (and all codes and ordinances issued in relation to such
4. Record keeping and auditing
The Company is subject to accounting regulations and requirements which oblige it to account faithfully and
exactly for all of its assets and liabilities, and all of its commercial transactions. The Company will therefore keep full
and accurate financial records and have appropriate internal controls in place which will evidence the business reason
for making payments to third parties. The Company’s accounts are audited annually by independent auditing firms.
5. Conflicts of Interest
The Company expects that the Company’s Employees and third parties engaged by, or on behalf of, the
Company will always act in the Company's best interests and avoid any situation where their personal interests
(financial, political, professional or other interests), or those of persons close to them (family or friends), might conflict
with their obligations towards the Company, and the Company expects that all such parties will in all circumstances
conduct themselves with integrity and avoid any conflict(s) of interest.
6. Patronage and Sponsorship
The Company takes part in certain sponsorship operations where, in exchange for financial or material
support for an event, it gains a certain visibility. Each such patronage and sponsorship action is the subject of prior
verification as to the reputation and legitimacy of the bodies, associations and companies that are to be supported,
and its compliance with laws and regulations in force in the relevant country.
7. Suppliers and Intermediaries
The Company conducts prior due diligence when engaging with or hiring of any new supplier or new service
provider or new intermediary, taking into account the skills, professionalism, capacity and reputation of such parties
(and expects that any such engagement will be integrated into a defined contractual framework).
The Company manages its activities in compliance with the rules of free competition, and requires its
employees to apply, and comply with, legislation and regulations pertaining to competition law in all countries in which
the Company (or any relevant group company or subsidiary) does business. The Company itself engages in vigorous
and fair competition, keeping the interests of its customers and partners in mind.
9. Internal Reporting (Whistleblowing) Procedure
The Company also operates a reporting (so-called “whistleblowing”) procedure (Internal Alert Procedure)
which is an integral part of the Company’s Code of Conduct. Such Internal Alert Procedure relates to circumstances
where: (i) a criminal offence has been or is likely to be committed; (ii) there has been or is likely to be a failure to comply
with a legal obligation; (iii) a miscarriage of justice has occurred, is occurring or is likely to occur; (iv) the health and
safety of any individual is or is likely to be endangered; (v) there is, has been or is likely to be damage to the environment;
or (vi) there is, has been or is likely to be a deliberate concealment of information relating to any of the above. The
Internal Alert Procedure provides each Employee of the Company with guidelines regarding the signaling of any
criminal offence and/or any breach of the Company's legal obligations and/or relevant law(s). Any alerts under the
Internal Alert Procedure will be promptly and fully investigated by the Company.