Anti-Bribery and Corruption Policy

We are committed to preventing bribery, corruption, fraud, and other unethical practices in all its business dealings.  The purpose of this policy is to ensure that all employees, contractors, and third parties acting on behalf of the organisation conduct business with integrity, transparency, and in compliance with applicable laws, including the UK Bribery Act 2010 and anti-money laundering regulations.

Scope

This policy applies to:

  • All employees, directors, and officers
  • Contractors, consultants, agents, and intermediaries acting on behalf of the organisation
  • Subsidiaries, joint ventures, and business partners over which the organisation has control

It covers all business activities, including dealings with government bodies, clients, suppliers, and charitable organisations.

Commercial Bribery

Employees and representatives must not offer, promise, give, request, or accept any bribe or improper advantage to gain or retain business or influence a business decision.

  • Commercial bribery includes:
  • Kickbacks, secret commissions, or other inducements
  • Payments or gifts intended to secure an improper business advantage

Falsification of Company Books and Records

All financial and non-financial records must be accurate, complete, and transparent.

Employees must not:

  • Make false entries in accounts or records
  • Conceal transactions or misstate liabilities, revenues, or assets
  • Create off-the-books accounts or undisclosed funds
  • Any suspicious activity must be reported immediately to management or via the whistleblowing mechanism.

Dealing with Government Intermediaries

Interactions with government officials or intermediaries must:

  • Be fully transparent and documented
  • Avoid improper influence or inducement
  • Comply with all relevant anti-bribery, lobbying, and procurement laws

Payments to government intermediaries must be pre-approved and properly recorded.

Charitable Contributions

Charitable donations or sponsorships must:

  • Be genuine and for legitimate purposes
  • Not be used as a disguise for bribery
  • Be approved in advance by management
  • Be fully documented in the company’s accounts

Money Laundering

The organisation will not participate in or facilitate money laundering. Employees must:

  • Verify the identity of clients, suppliers, and business partners where required
  • Report suspicious transactions to management or the Money Laundering Reporting Officer
  • Ensure all payments are lawful and traceable

Gifts and Entertainment

Gifts, hospitality, or entertainment must be:

  • Reasonable, proportionate, and transparent
  • Approved according to company thresholds
  • Never intended to secure an improper advantage

Employees must decline or report gifts that could influence, or appear to influence, business decisions.

Conflicts of Interest

Employees must avoid situations where personal interests conflict with company interests.

This includes:

  • Financial or personal relationships with clients, suppliers, or competitors
  • Accepting gifts or benefits that could influence judgement
  • Undertaking outside activities that compete with or damage the organisation

Conflicts must be declared to line management.

Whistleblowing / Grievance Mechanism

Employees are encouraged to report:

  • Suspected bribery, corruption, or fraud
  • Breaches of this policy
  • Any other unethical or illegal conduct

Reports can be made confidentially and without fear of retaliation, via the company’s managing director.

Facilitation Payments

The organisation prohibits facilitation or “grease” payments, regardless of local customs.

No employee or representative should make payments to secure or expedite routine government actions.

Relationships with Third Parties

All third parties acting on behalf of the organisation must:

  • Comply with this policy
  • Be vetted for integrity and risk before engagement
  • Be bound contractually to anti-bribery and anti-corruption obligations

Managers must ensure ongoing monitoring of third-party compliance.

Cartels or Market Rigging

Employees must not engage in anti-competitive behaviour, including:

  • Price-fixing or market-sharing agreements
  • Bid-rigging or collusion with competitors
  • Any activity that breaches competition law

Any suspected cartel activity must be reported immediately.

Independent Investigation or Adjudication

All reports of bribery, corruption, or policy breaches will be:

  • Investigated promptly, independently, and confidentially
  • Documented with evidence
  • Escalated to management, legal, or external investigators as required

Corrective and disciplinary actions will be taken, up to and including termination or legal prosecution.

Training and Awareness

The organisation will provide:

  • Regular training for employees on anti-bribery, corruption, and related compliance topics
  • Guidance for managers on risk identification and mitigation
  • Updates on legislative changes and industry best practices

Consequences of Breach

Non-compliance may result in:

  • Disciplinary action, including dismissal
  • Termination of contracts with third parties
  • Civil or criminal prosecution under UK law

Review

This policy will be reviewed at least annually or following significant legislative, operational, or organisational changes.

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Approved By:   R Gauldie, Director

5th February 2026