Website Terms and Conditions

Please read these Terms and Conditions carefully as they contain important information about your rights and obligations. We recommend that you keep a copy of these Terms and Conditions and that you print out these Terms and Conditions from GradTouch (as defined below) by clicking on the “Print” icon on your browser so that you can keep them for future reference. Use of and access to GradTouch is also subject to our Privacy and Cookies Policy .

1. ABOUT US AND THESE USER TERMS:

1.1 About us: “we”, “us” or “ our” means GradTouch Limited, a company registered in England and Wales under company number 07718853 and with registered office at The Copper Room Deva City Office Park, Trinity Way, Manchester, England, M3 7BG.

1.2 These Terms and Conditions: These Terms and Conditions govern your access to and, if you choose to do so, registration for a user account for access to, our graduate candidate platform for searching, and applying, for jobs at www.gradtouch.com (“ GradTouch”). By submitting your details to us for registration for an account on GradTouch, you agree to be legally bound by these Terms and Conditions.

1.3 Changes to these Terms and Conditions: We reserve the right to amend these Terms and Conditions at any time. All amendments to these Terms and Conditions will be posted on GradTouch and emailed to you if you have registered for an Account (as defined below). Continued use of GradTouch will, however, be deemed to constitute acceptance of the new Terms and Conditions. No other terms or changes to these Terms and Conditions will be binding unless agreed in writing signed by us. Any changes to these Terms will not affect your right to cancel your Account or restrict the information you have shared with us.

1.4 Definitions and interpretation: In these Terms and Conditions:

1.4.1 the following terms shall have the following meanings:

1.4.2 references to “Clauses” are to clauses of these Terms and Conditions;

1.4.3 the headings are inserted for convenience only and shall not affect the interpretation or construction of these Terms and Conditions;

1.4.4 words imparting the singular shall include the plural and vice versa. Words imparting a gender shall include the other gender and the neutral, and references to persons shall include an individual, company, corporation, firm or partnership;

1.4.5 reference to “written” or in “ writing” includes the electronic form;

1.4.6 references to “includes” or “ including” or like words shall mean without limitation; and

1.4.7 references to any statute or statutory provision shall include any subordinate legislation made under it, any provision which it has modified or re-enacted (whether with or without modification) and any provision which subsequently supersedes it or re-enacts it (whether with or without modification).

2. RESTRICTED ACCESS

By access the Services and/or registering for an Account, you warrant that you are over the age of 16.

3. EFFECT

3.1 Application of these Terms and Conditions: These Terms and Conditions shall apply to all use of the Services and an Account. Each time you visit GradTouch, and when you register for an Account (and each time you subsequently login to your Account), this shall always constitute your unqualified acceptance of these Terms and Conditions (or, in accordance with Clause 1.3, the Terms and Conditions then in force). Nothing in these Terms and Conditions shall affect your statutory rights.

3.2 We do not accept any other terms: These Terms and Conditions shall prevail over any separate terms put forward by you. Any conditions that you submit, propose or stipulate in whatever form and at whatever time, whether in writing or orally, are expressly waived and excluded.

4. REGISTRATION FOR AN ACCOUNT

4.1 Need for an Account: If you would like to be able to manage your job preferences, receive updates on available roles, have a profile within GradTouch for Employers to view, and apply for roles listed on GradTouch (the “ Registration Benefits”), you will need to register for an account on GradTouch which you will be able to access through the “Sign In” part of GradTouch, and by which you will be able to change the details that we hold about you and administer and access the Services that we provide to you (“Account”). You may browse GradTouch for individual roles with Employers without registering for an Account, but, to access the Registration Benefits, you must register for an Account.

4.2 If you have an Account: If you already have an Account, you can login to your Account to access the Services.

4.3 If you do not have an Account: To register for an Account and access the Registration Benefits, you need follow the instructions on GradTouch and supply us with your name, email address, a password and possibly some other personal information. You will be asked to create a “profile” for your Account that can be viewed by Employers. See our Privacy and Cookies Policy for more details about this. You can provide us with that information by filling in the necessary information on GradTouch manually where indicated and then following the instructions on GradTouch.

4.4 Access details for an Account: Once you register for an Account, you will be asked to create a username and password for your Account. You may change this password by accessing your Account and following the instructions. You must keep the password confidential and immediately notify us if there is any unauthorised use of your email address or your Account or any breach of security otherwise known to you. You acknowledge that any person to whom your username or password is disclosed is authorised to act as your agent for the purposes of using your Account. Please note that you will be entirely responsible if you do not maintain the confidentiality of your password.

4.5 Email address: You must be registered for an Account with a valid email address that you access regularly, so that, amongst other things, we can send administration and information emails to you. Any Account registered with another person’s email address or with a temporary email address may be closed by us without notice. We may also require you to validate your Account at registration or if we believe that you have been using an invalid email address.

4.6 Rejection: We reserve the right to reject any registration for an Account and to refuse use of or access to GradTouch to anyone for any reason, at our absolute discretion.

4.7 One Account: You will only maintain one Account at any time.

5. THE SERVICES

5.1 Accessing the Services: In order to access the Services, you will need to visit GradTouch and, if applicable, login to your Account. You should follow the instructions within GradTouch and (if applicable) your Account to access the Services you require.

5.2 Registration Benefits: If we accept your registration for an Account, we shall provide to you access to the Registration Benefits. Your profile that you create through your Account will be visible to Employers using GradTouch, and those Employers will have the option of communicating with you informing you of their interest in you for a particular role. You may also contact Employers about particular roles listed on GradTouch. You can, but you are not obligated to, communicate with, or respond to, Employers in respect of particular roles. You may be able to apply for particular roles through GradTouch, or visit the Employer’s (or its nominated third party’s) website in order to make such application (for which you will require an Account, but you will not need to use all of your Account login information to make such application).

5.3 Our warranties: We warrant that:

5.3.1 we shall use our reasonable skill and care in providing the Services;

5.3.2 we have all necessary consents, rights and permission to enter into, and perform our obligations under, these Terms and Conditions; and

5.3.3 we shall comply with all applicable laws, statutes, regulations and bye-laws in relation to the exercise of our rights and performance of our obligations under this Agreement.

5.4 Appearance of GradTouch: The look-and-feel of GradTouch, and the way in which the Services and any content you create or upload appears to users of GradTouch, shall be decided at our absolute discretion.

5.5 No warranty: We do not warrant that the Services will meet your individual requirements. We are not responsible for any connections, deliverables or services that we are not expressly stipulated to provide in these Terms and Conditions. You acknowledge that your use of the Services does not guarantee you any interest from Employers, or that any application you make will be successful, and that you may not secure any interviews or job offers, or any particular salary, by using the Services.

5.6 No guarantee: We do not warrant that the Services will be uninterrupted, error-free or secure from unauthorised access, or that they will meet your individual requirements. Whilst we use our reasonable endeavours to make the Services available, we shall not have any liability (subject to Clause 12.2) if for any reason the Services are unavailable for any time or for any period. We make no warranty that your access to the Services will be uninterrupted, timely or error-free. Due to the nature of the Internet, this cannot be guaranteed.

5.7 Improvements: We reserve the right, at any time, to carry out repairs, maintenance or introduce new facilities and functions in respect of all or any part of the Services.

5.8 Our responsibility: Except as specifically stipulated in these Terms and Conditions, we shall not be responsible for providing or achieving any particular results or outcomes or within a particular time.

5.9 Exclusions: Except where expressly stated in these Terms and Conditions, we exclude all conditions, warranties, terms and obligations, whether express or implied by statute, common law or otherwise, to the fullest extent permitted by law in respect of the Services.

5.10 No warranty as to compatibility: We do not warrant that the Services will be compatible with all Material.

6. YOUR OBLIGATIONS

6.1 What we do with the information you share: If you share your CV or other Material with us in creating your Account or applying for roles available through GradTouch, you consent to our sharing of that information with Employers, and you grant to us:

6.1.1 a non-exclusive, royalty-free licence in respect of your CV and information (including any intellectual property rights in or to it) to share that information to the extent we reasonably require in order to provide the Services; and

6.1.2 the right to grant a perpetual, royalty-free sub-licence of that information to Employers for their recruitment activities.

For more information about how we use your personal data, please see our Privacy and Cookies Policy .

6.2 Correct information: By adding Material to GradTouch, you warrant to us and any other user of GradTouch that the information you add is true, accurate, current and complete, is not misleading or otherwise deceptive and is up-to-date. You should choose the Material you share with us carefully.

6.3 Updating information: You are responsible for maintaining and updating information and content in any Material you add to GradTouch or otherwise provide to us through your use of the Services. If you:

6.3.1 provide false or incorrect information and/or content; and/or

6.3.2 do not update changes to such information and/or content promptly;

we reserve the right to terminate your use of the Services immediately and without notice to you.

6.4 Restrictions on use: You shall not use the Services in any way, or add any Material to GradTouch, which in any respect:

6.4.1 breaches any law, statute, regulation or byelaw of any applicable jurisdiction;

6.4.2 is inaccurate, misleading or out-of-date;

6.4.3 may be contrary to our interests;

6.4.4 is criminal, fraudulent or unlawful;

6.4.5 is obscene, indecent, pornographic, profane, racist, vulgar, sexist, discriminatory, offensive, harmful, threatening, abusive, malicious, hateful, defamatory or derogatory;

6.4.6 is a misrepresentation;

6.4.7 is intended to sell or commercially exploit any products or services;

6.4.8 infringes or breaches, or may infringe or breach, the Intellectual Property Rights or privacy or other rights of us or any third party;

6.4.9 is contrary to any rule or requirement that we stipulate; or

6.4.10 involves your use, delivery or transmission of any viruses, unsolicited communications, Trojan horses, trap doors, cancelbots, back doors, worms, easter eggs, time bombs or computer programming routines that are intended to damage, interfere with, surreptitiously intercept or expropriate any data, personal information or system.

6.5 For personal use only: The Services are for your personal use only. You must not use or access the Services on behalf of any other person, or for business or other commercial purposes.

6.6 No automated access: You shall not use any automated means (such as scripts) to access the Services or your Account, or collect any information from GradTouch, unless we explicitly agree in writing to allow you to do so.

6.7 No linking: When you add Material to GradTouch, you must not include any links (text, graphical or otherwise) unless you have permission from the owner of the link URL to do so.

6.8 No liability for your information: We shall not have any liability (subject to Clause 12.2) for information or content (including Material) that you add to your Account or GradTouch which is in breach of any provision of these Terms and Conditions or any applicable law. You warrant that any such contribution does comply with those standards, and you will be liable to us and indemnify us for any breach of that warranty. We have the right to disclose your identity to any third party who is claiming that any content posted or uploaded by you to GradTouch constitutes a violation of their Intellectual Property Rights, or of their right to privacy. We will not be responsible and we shall not have any liability (subject to Clause 11.2) to any third party for the content or accuracy of any content posted by you.

6.9 Connecting with other users: You are exclusively responsible for your interactions with other users of the Services (including Employers). We may limit the number of connections you may have to other users and may, in certain circumstances, prohibit you from contacting other users through use of the Services, or otherwise restrict the way in which you may use the Services. We reserve the right, and have absolute discretion, but not an obligation, to monitor disputes between you and other users and to restrict, suspend or close Accounts if we determine, at our absolute discretion, that doing so is necessary to protect the Services.

6.10 Our rights: We retain the right to, if we consider it to be appropriate:

6.10.1 immediately halt access to Services;

6.10.2 prevent or restrict access to the Services; and/or

6.10.3 take any other action to preserve and protect the Services and/or restrict access to or availability of or remove any objectionable material, inaccurate listings or any other material or listings that is prohibited by these Terms and Conditions.

6.11 No moderation: We reserve the right, and have absolute discretion, but not an obligation, to remove, screen or edit any content (including Material) that breaches these Terms and Conditions or is otherwise objectionable. Without prejudice to any other provision of these Terms and Conditions, we reserve the right to immediately remove any listings to which we object (including your use of Intellectual Property Rights) and/or if you are otherwise making inappropriate use of the Services contrary to the requirements of these Terms and Conditions.

6.12 No liability for third parties: We shall not have any liability (subject to Clause 11.2) for:

6.12.1 damage to, or viruses or other code that may affect, any computer equipment, software, data or other property as a result of your access to or use of the Services or you obtaining any material from, or as a result of using, the Services;

6.12.2 the actions of third parties;

6.12.3 any job that you may or may not obtain as a result of the Services;

6.12.4 profiles created and posted by Employers on GradTouch and any information or content contained in them, including links to other websites; and/or

6.12.5 your access to any third-party website through the Website, and for the content, accuracy or opinions expressed on such websites; we do not investigate, monitor or check such websites, and the inclusion of any such link on the Website does not imply that we approve of or endorse that website, and you access such websites at your own risk.

6.13 Suspension or withdrawal of access: Access to the Services may be suspended or withdrawn to or from you or all users temporarily or permanently at any time without notice. We may also impose restrictions on the length and manner of usage of any part of the Services or access for any reason. If we impose restrictions on you, you must not attempt to use the Services (or the relevant part of them) under any other name or user.

6.14 Changes: We may change or update the Services and anything described in them without notice to you.

6.15 No warranty: Whilst we endeavour to ensure that information and materials available through the Services are correct, no warranty or representation, express or implied, is given that they are complete, accurate, up-to-date, fit for a particular purpose and, to the extent permitted by law and we shall not have any liability (subject to Clause 12.2) for any errors or omissions.

6.16 No impersonation: You shall not impersonate any person or use a name that you are not legally authorised to use. If you provide false or incorrect information or do not notify us of changes to your information or content immediately, we reserve the right to terminate your access to the Services without notice.

6.17 Your responsibilities: You shall:

6.17.1 report any faults or suspected faults with or in the Services to us immediately upon discovery;

6.17.2 report to us any abuse of the Internet (including spam, hacking and phishing) that you consider to have taken place through the use of the Services by any person, and you shall include in such report as much information as you are able to provide to us relating to the type of abuse that you have witnessed;

6.17.3 use your own login details for the Services and not impersonate any other person or adopt a false identity;

6.17.4 keep your password strictly confidential and secure, and immediately change your password if you know or suspect that any unauthorised third party becomes aware of your password or if you become aware of unauthorised use of your password or there is any other breach of security known or suspected by you;

6.17.5 maintain access to the Services through your Internet or telecoms service providers, and we are not responsible for any connections from your system to the Services;

6.17.6 be responsible for ensuring that you have the knowledge and expertise necessary to access and make use of the Services;

6.17.7 ensure that all Material is suitable and prepared for use in conjunction with the Services;

6.17.8 promptly comply with our reasonable requests from time to time in connection with these Terms and Conditions; and

6.17.9 ensure that the Services are sufficient and suitable for your purposes and meet your individual requirements.

6.18 Warranty as to Material: You warrant that any Material is owned by you or you have in place appropriate consents to use that Material in the way in which you do you use it. It is your responsibility to make sure that you have all necessary rights and consents relating to your use of the Material in conjunction with the Services.

6.19 Indemnity as to Material: You shall indemnify and hold us harmless against all liabilities, costs, expenses, damages and losses (including any direct or indirect consequential losses, loss of profit, loss of reputation and all interest, penalties and legal and other reasonable professional costs and expenses) suffered or incurred by us arising out of or in connection with any breach by you of Clauses 6.2, 6.17 or 6.18.

6.20 Keeping content confidential: When you post Material on GradTouch, it may be seen and used by other users of the Services (including Employers). Other users may use that information and content for their own purposes, and you acknowledge that we have no control over, and cannot guarantee, that use. If there is Material that you want to keep confidential, or you would prefer others not to use it, do not post it to GradTouch. We shall not be responsible and we shall not have any liability (subject to Clause 12.2) for the misuse by third parties of any information and content that you post on GradTouch.

6.21 Content from other users: You will have access to content and information posted on GradTouch by other users and third parties (including Employers). You acknowledge that much of the content of and information on GradTouch is user-generated. We reserve the right, and have absolute discretion, but not an obligation, to monitor and filter that content and information; you acknowledge that you rely on such content and information at your own risk and that we shall not have any liability (subject to Clause 12.2) for that content and information and any reliance you place on it.

7. OUR ROLE

7.1 Limited role: You acknowledge that, in providing the Services to you and listing roles for Employers on GradTouch, we do not act as an employment agency. We facilitate you connecting, and communicating, with Employers.

7.2 Your responsibility to check: You and the Employers are exclusively responsible for the information that each makes available to the other, in any way, through use of the Services, GradTouch or otherwise. You are responsible for all background checks you should sensibly make before communicating with, interviewing with or accepting employment with any Employer as to the appropriateness of that Employer to your requirements.

7.3 Your agreement with the Employer: We are not party to, or liable under (subject to Clause 12.2), any agreement you have with any Employer, and you and the Employer are responsible to each other for any breach of such agreement.

8. FEES

Access to the Services and GradTouch, and registration for an Account, is currently free of charge.

9. DATA PROTECTION

9.1 Personal information you submit: Any information and content that you submit to GradTouch in accessing the Services may become public information. If that information or content includes your personal information, you consent to the public availability of that personal information by submitting it to GradTouch unless you change your subscriptions or deactivate your Account, by changing your Account settings. Deactivating your Account means that you can no longer access it and your profile no longer appears on GradTouch for Employers to view, but the background information it contains remains on our systems; to fully delete your Account, please see Clause 11.1.

9.2 Privacy and Cookies Policy: Please see our Privacy and Cookies Policy which forms part of these Terms and Conditions.

10. INTELLECTUAL PROPERTY RIGHTS

10.1 What we own: You acknowledge that we own:

10.1.1 all Intellectual Property Rights in the Services and any rights arising out of any works arising in connection with them; and

10.1.2 any URLs and web-addresses that may be assigned to the content that you create.

We grant to you a non-exclusive licence to access the Services in accordance with these Terms and Conditions.

10.2 What you own: We acknowledge that you own all Intellectual Property Rights in the Material, where your ownership is subject to the obligations contained in these Terms and Conditions and, in particular, Clause 6. You grant to us a non-exclusive licence to use that Material to the extent necessary for us to provide the Services to you and to retain that Material following any termination of this Agreement to the extent that we consider reasonably necessary.

11. TERMINATION

11.1 Term: This Agreement will continue in force until either we or you close your Account, or you otherwise cease to use the Services. To close your Account, contact us at info@gradtouch.com.

11.2 Termination at any time: We may terminate this Agreement with immediate effect at any time by giving notice to you, except where you are in breach of this Agreement, in which instance we may terminate this Agreement at any time without notice. You may terminate this Agreement with immediate effect at any time by closing your Account by using the functionality available within your Account.

11.3 On termination: In the event that this Agreement terminated:

11.3.1 you will cease to have access to the Services; and

11.3.2 the accrued rights, remedies, obligations and liabilities of us and you as at cancellation or termination shall not be affected, including the right to claim damages for any breach of these Terms and Conditions which existed at or before the date of cancellation or termination.

11.4 Post-termination: Termination of the Agreement shall not affect the coming into force, or continuance in force, of any provision which is expressly or by implication intended to come into or continue in force on or after such termination.

12. LIMITATION OF LIABILITY

12.1 We are responsible to you for foreseeable loss and damage caused by us: If we fail to comply with the Agreement, we are responsible for loss or damage you suffer that is a foreseeable result of our breaking the Agreement or our failing to use reasonable care and skill, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time the contract was made, both we and you knew it might happen.

12.2 We do not exclude or limit in any way our liability to you where it would be unlawful to do so: This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors; for fraud or fraudulent misrepresentation.

12.3 We are not liable for business losses: We only provide to you access to the Services for domestic and private use. If you use the Services for any commercial, business or re-sale purpose, we will have no liability to you (subject to Clause 12.2) for any loss of profit, loss of business, business interruption, or loss of business opportunity.

13. GETTING IN CONTACT

If you wish to contact us in writing, or if any Clause in these Terms and Conditions requires you to give us notice in writing, you can send this to us by e-mail, by hand, or by pre-paid post to GradTouch Limited at Work.Life, Core, Brown Street, Manchester, M2 1DH and info@gradtouch.com. We will confirm receipt of this by contacting you in writing. If we have to contact you or give you notice in writing, we will do so by e-mail, by hand, or by pre-paid post to the address you provide to us when registering for an Account.

14. COMPLAINTS

We value your satisfaction with the Services. You may contact us at any time at info@gradtouch.com. We will try to address any concerns you may have as soon as reasonably possible and we will contact you when we receive any relevant enquiry or complaint from you.

15. GENERAL

15.1 Third party rights: A person who is not us or you shall not have any rights under or in connection with these Terms and Conditions.

15.2 Transfer by you: These Terms and Conditions are personal to you. You may not assign, transfer, charge or otherwise encumber, create any trust over, or deal in any manner with, these Terms and Conditions or any right, benefit or interest under them, nor transfer, novate or sub-contract any of your obligations under them, without our prior written consent (and we will not unreasonably withhold or delay our consent).

15.3 Waiver: If we fail to insist that you perform any of your obligations under these Terms and Conditions, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations. If we do waive a default by you, we will only do so in writing, and that will not mean that we will automatically waive any later default by you.

15.4 Severance: Each of the provisions of these Terms and Conditions operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining provisions will remain in full force and effect.

15.5 No partnership: Nothing in these Terms and Conditions shall constitute a partnership or employment or agency relationship between us and you.

15.6 Governing law: These Terms and Conditions and any dispute or claim arising out of or in connection with them (including non-contractual disputes or claims) shall be governed by and construed in accordance with English law.

15.7 Jurisdiction: You submit to the exclusive jurisdiction of the English courts to settle any dispute or claim arising out of or in connection with these Terms and Conditions or their subject matter or formation, except where, by law, such dispute or claim must be brought in the jurisdiction in which you are domiciled, or where the relevant law contains mandatory provisions that override such exclusive jurisdiction.

16. ELECTRONIC COMMUNICATION DISCLAIMER

16.1 Emails sent from the domain gradtouch.com are issued by GradTouch Limited registered in England and Wales under company number 07718853.

16.2 Emails are confidential and may be protected by legal privilege and may be read, copied and used only by the intended recipient. If you are not the intended recipient(s), do not copy it, forward it or disclose its contents to any other person, as this is strictly prohibited, and if you have received it in error please delete. An email is made available in the United Kingdom to Professional Clients and Eligible Counterparties as defined by the FCA.

16.3 Persons who have received a communication should not rely upon it alone, and should seek professional advice if necessary. Any attachments are in accordance with COBS 2.4 in the FCA Handbook on www.fca.org.uk (reliance on others).GradTouch Limited is taking a proportionate approach and has verified all documents to the best of its ability. If you consider the contents (including attachments) are material to the formation of a contract, or you are otherwise relying upon its accuracy, you may wish to request a copy to be sent by normal mail.

16.4 GradTouch Limited can not guarantee the accuracy or completeness of an email as information could be intercepted, corrupted, lost, destroyed and incomplete or arrive late, or contain viruses when transmitted over the public networks. If you suspect that an email may have been intercepted or amended, please contact the sender. When addressed to GradTouch Limited’s clients, any opinion or advice contained in an e-mail is subject to GradTouch’s terms of business. This e-mail is provided for informational purposes only and should not be construed as a solicitation or offer to buy or sell securities or related financial instruments.

16.5 We are not liable for any damage that an email or its content may cause to your computer system.

16.6 Visiting and Mailing address is: GradTouch Limited, Work.Life, Core, Brown Street, Manchester, M2 1DH. Our administration department can be reached on: +44 (0)161 236 2932 or info@gradtouch.com

17. ANTI-BRIBERY AND CORRUPTION POLICY

17.1 Introduction: GradTouch Limited values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:

17.1.1 Setting out a clear anti-bribery policy;

17.1.2 Training all consultants and clients, so that they can recognise and avoid the use of bribery by themselves and others;

17.1.3 Encouraging its consultants and clients to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;

17.1.4 Notifying all third parties that the Board of Directors engage with of its policy and zero tolerance of bribery and/or corruption.

17.1.5 Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution;

17.1.6 Taking firm and vigorous action against any individual(s) involved in bribery.

17.2 The Policy: GradTouch Limited prohibits the Board of Directors in:

17.2.1 the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company by any individual consultant, agent or other person or body acting on the Board of Directors' behalf in order to gain any commercial, contractual or regulatory advantage for the Board of Directors 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.

17.3 Further clarification: The Board of Directors recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Board of Directors or of the person or body employing or contracting with them or whom they represent.

17.4 This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:

17.4.1 normal and appropriate hospitality

17.4.2 the giving of a gift for a corporate reason or at another special time, as long as reported in the proper manner within the firm on the gifts register

17.5 Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the local senior manager with responsibility for this policy before proceeding. If necessary, guidance should also be sought from the Compliance Officer.

17.6 Consultants and Principles Responsibility within GradTouch Limited: The prevention, detection and reporting of bribery is the responsibility of all consultants throughout the Board of Directors. Suitable channels of communication by which consultants or others can report confidentially any suspicion of bribery will be maintained via the Anti-Corruption Reporting procedures. Useful resource: www.transparency.org.uk for the Transparency Index.