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Anti-Bribery and Corruption Policy

Last Updated: 04/12/25

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1. Introduction

[Company Name] (“the Company”) is committed to conducting business with honesty, integrity, and transparency. We have a zero-tolerance approach to bribery and corruption in all forms. This policy outlines our responsibilities, the responsibilities of those working for or with us, and the standards expected to ensure compliance with the UK Bribery Act 2010.

2. Purpose of This Policy

This policy is designed to:

  • Prevent bribery and corruption in all business activities.

  • Ensure compliance with the UK Bribery Act 2010.

  • Protect the Company’s reputation and ethical standards.

  • Provide guidance to employees, contractors, suppliers, and partners.

3. Scope

This policy applies to:

  • All employees (permanent, temporary, agency).

  • Contractors, consultants, and self-employed individuals.

  • Suppliers, service providers, and business partners.

  • Anyone acting on behalf of the Company within the UK or internationally.

4. What is Bribery?

Bribery involves offering, promising, giving, requesting, agreeing to receive, or accepting a financial or other advantage to influence the actions of another person or organisation.

Examples include (but are not limited to):

  • Cash payments.

  • Gifts or hospitality intended to influence decisions.

  • Kickbacks or facilitation payments.

  • Favourable treatment in return for personal gain.

Bribery is illegal regardless of:

  • Whether the bribe is accepted or rejected.

  • Whether the bribe benefits the Company or the individual.

5. Prohibited Conduct

The Company strictly prohibits:

  • Offering or accepting bribes.

  • Making facilitation payments (small payments made to expedite routine processes).

  • Offering excessive gifts or hospitality to influence decisions.

  • Engaging in corrupt behaviour toward public officials.

  • Making unofficial payments or donations on behalf of the Company.

  • Any attempt to circumvent controls relating to bribery prevention.

6. Gifts, Hospitality & Entertainment

Reasonable, proportionate hospitality may be allowed if it:

  • Has a legitimate business purpose.

  • Is approved according to Company procedures.

  • Is not intended to influence a decision or secure improper advantage.

Employees must not accept or give:

  • Cash gifts.

  • Anything lavish or inappropriate.

  • Hospitality during sensitive negotiations.

All gifts or hospitality above a defined threshold must be recorded and approved (you can add your own value limit here if desired).

7. Charitable Donations & Sponsorship

The Company may make charitable donations or sponsorships, but:

  • They must be transparent and properly recorded.

  • They must not be used as a substitute for bribery.

  • Employees must not solicit donations for improper purposes.

8. Responsibilities

Company Responsibilities

We will:

  • Maintain effective anti-bribery training and communication.

  • Implement monitoring, due diligence, and risk-management procedures.

  • Take action against anyone found to be in breach of this policy.

Employee Responsibilities

Employees must:

  • Read, understand, and comply with this policy.

  • Report concerns or suspected bribery promptly.

  • Avoid any activity that could lead to a breach.

9. Reporting Concerns

Employees and third parties who suspect any form of bribery or corruption must report their concerns through internal reporting channels, such as:

  • Line manager or supervisor

  • Senior management

  • HR or compliance representative

  • Dedicated internal reporting email (if applicable)

Reports cannot be submitted directly through the website.

The Company encourages open communication and will ensure that:

  • All reports are treated confidentially.

  • Individuals will not suffer retaliation for reporting concerns in good faith.

10. Consequences of Non-Compliance

Breaches of this policy may result in:

  • Disciplinary action up to and including dismissal.

  • Termination of relationships with contractors or suppliers.

  • Civil or criminal penalties under the UK Bribery Act 2010.

11. Due Diligence

The Company will conduct proportionate due diligence on:

  • Suppliers

  • Contractors

  • Agents

  • Third-party representatives

Particularly where higher risks of bribery exist.

12. Policy Review

This policy will be reviewed annually and updated when necessary to reflect:

  • Changes in legislation

  • Best practice guidance

  • Company operational needs

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