Anti-Corruption and Bribery Policy

Baronsmead VCT 4 plc (the "Company") Anti-Corruption and Bribery Policy

A zero-tolerance approach is taken by the Board of Baronsmead VCT 4 plc to bribery and corruption. The Board are committed to acting professionally, fairly and with integrity at all times. Accordingly it expressly prohibits any Director or associated persons, when acting on behalf of the Company, from accepting, soliciting, paying, offering or promising to pay, or authorising any payment, public or private, in the United Kingdom or abroad to secure any improper benefit for them self or for the Company.

Bribery is the accepting of gifts, money, hospitality or other favours in return for providing something of value to the briber. The purpose of this policy is to set out the rules that must be followed to ensure that no bribery occurs.

The Bribery Act 2010 contains two general offences covering the offering, promising or giving of a bribe and the requesting, agreeing to receive or accepting of a bribe. It also sets out two further offences which specifically address commercial bribery: one relating to the bribery of a foreign public official in order to obtain or retain business or an advantage in the conduct of business and one creating a new form of corporate liability which an organisation can commit by failing to prevent bribery of any of its employees, subsidiaries, agents or service providers or other associated persons (defined as a person who “performs services” for or on behalf of an organisation and may include employees, contractors, agents, service providers and subsidiaries) in an attempt to obtain or retain business or a business advantage both in the UK or internationally.

The Directors of the Baronsmead VCT 4 plc recognise their responsibilities in ensuring that the Company has a robust policy to avoid such practices and to ensure compliance with its legal obligations. The Board has requested that it is informed immediately of any identified instances of bribery or corruption within any of its principal service providers. On an annual basis, principal service providers are required to confirm to the Company that an anti-bribery policy and adequate procedures are in place and report any identified instances of bribery or corruption and details of the corrective courses of action taken.

As part of a risk based approach, the Board has delegated to the Audit Committee, the task of carrying out an annual risk assessment on matters relating to bribery, involving due diligence enquiries in respect of persons who perform or will perform services for or on behalf of the Company, in order to mitigate identified risks.

The Audit Committee will review this policy and procedures at least annually and report back to the Board who will ensure that it is publicly available both on the Company’s website and also in its Annual Report & Accounts.

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