Anti-Bribery, Corruption and Fraud Policy

People acting for a Participating Business must not:

1. offer, promise, give, request or accept an improper advantage;
2. make unofficial payments to secure or accelerate routine action;
3. submit false invoices, expenses, records or evidence;
4. conceal ownership, conflicts, commissions or side arrangements;
5. manipulate tenders, quotations or supplier selection; or
6. use a third party to do anything prohibited by this policy.

Reasonable and proportionate hospitality may be permitted only where it is lawful, transparent, infrequent and incapable of influencing a decision. Cash gifts and cash equivalents are prohibited.

Participating Businesses apply risk-based checks to suppliers, representatives and material transactions. Payments and expenses must have a legitimate purpose, appropriate authority and accurate supporting records.

Suspected misconduct must be reported promptly to the relevant Participating Business. Reports are assessed, evidence is protected and appropriate investigation or referral is made. Retaliation against a person raising a genuine concern is prohibited.

Confirmed misconduct may lead to removal, termination, recovery action and reporting to law enforcement or regulators.

Risk is considered when appointing intermediaries, suppliers, labour, agents or partners; entering unfamiliar markets; making charitable or sponsorship payments; using cash; responding to public-sector opportunities; and approving unusual commissions, discounts or expenses. Proportionate identity, ownership, reputation and purpose checks are completed before commitment.

No person may offer, promise, give, request or accept a financial or other advantage intended to induce improper performance. Facilitation payments and secret commissions are prohibited. Genuine immediate threats to safety are reported and documented as soon as practicable. Political contributions are not made on behalf of a Participating Business without lawful, explicit approval and transparent recording.

Transactions require appropriate authority, a genuine business purpose, supporting evidence and accurate books. Payment-detail changes are independently verified. Duties are separated where proportionate, and unusual suppliers, duplicate invoices, round-sum payments, split purchases, unexplained urgency and conflicts receive challenge.

Investigations are impartial, need-to-know and evidence-led. Suspects are not alerted where doing so could prejudice lawful investigation or recovery. Privilege, employment rights, privacy, insurer conditions and reporting obligations are considered. Corrective action addresses both individual conduct and the control weakness that allowed it.

Approved by David Swaddle, Founder, on 30 August 2026.