Anti-Bribery & Corruption Policy

Our Commitment

We are committed to:

1. Zero Tolerance — Prohibiting bribery and corruption in all forms
2. Legal Compliance — Complying with the Bribery Act 2010 and all applicable anti-corruption laws
3. Ethical Conduct — Acting with honesty and integrity in all business dealings
4. Transparency — Being open and transparent in our business relationships
5. Accountability — Holding all associated persons accountable for compliance
6. Prevention — Implementing procedures to prevent bribery and corruption
7. Reporting — Encouraging the reporting of concerns without fear of retaliation

The Bribery Act 2010

The Bribery Act 2010 is the UK’s primary anti-corruption legislation. It creates four criminal offences:

Section 1 — Bribing Another Person

It is an offence to offer, promise, or give a financial or other advantage to another person with the intention of inducing or rewarding improper performance of a function or activity.

Section 2 — Being Bribed

It is an offence to request, agree to receive, or accept a financial or other advantage in return for the improper performance of a function or activity.

Section 6 — Bribing a Foreign Public Official

It is an offence to bribe a foreign public official with the intention of obtaining or retaining business or an advantage in the conduct of business.

Section 7 — Failure to Prevent Bribery

A commercial organisation is guilty of an offence if a person associated with it bribes another person intending to obtain or retain business or an advantage for the organisation. The only defence is to prove that the organisation had adequate procedures in place to prevent bribery.

Penalties

Individuals convicted of bribery offences can face:

• Up to 10 years’ imprisonment
• Unlimited fines

Organisations can face:

• Unlimited fines
• Exclusion from public contracts
• Reputational damage
• Director disqualification

What is Bribery?

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action which is illegal, unethical, or a breach of trust.

Examples of Bribery

Giving bribes:

• Offering cash payments to secure a contract
• Providing excessive hospitality to influence a decision
• Making payments to speed up a process (facilitation payments)
• Giving gifts to obtain confidential information
• Offering personal benefits to a client’s employee to win business
• Paying a subcontractor to overlook defects

Receiving bribes:

• Accepting cash or gifts in return for awarding a contract
• Receiving kickbacks from suppliers
• Accepting hospitality in return for favourable treatment
• Taking payments to approve substandard work
• Receiving personal benefits to influence a procurement decision

What is Not Bribery

Legitimate business activities are not bribery:

• Reasonable and proportionate hospitality
• Modest promotional gifts
• Genuine charitable donations
• Transparent sponsorship arrangements
• Normal business entertainment

The key distinction is intent — whether the advantage is intended to improperly influence a decision or action.

Prohibited Conduct

The following conduct is strictly prohibited:

You Must Not

• Offer, promise, or give a bribe to anyone
• Request, agree to receive, or accept a bribe from anyone
• Make or accept facilitation payments or “grease payments”
• Offer or accept gifts or hospitality intended to influence decisions
• Make payments to political parties or officials to obtain advantage
• Use agents or third parties to make improper payments on our behalf
• Create false records or documentation to conceal bribery
• Ignore or fail to report suspected bribery
• Retaliate against anyone who reports a concern in good faith

Facilitation Payments

Facilitation payments are unofficial payments made to public officials to secure or expedite routine actions. These are illegal under the Bribery Act 2010 and are strictly prohibited, regardless of local customs or practices in other countries.

Examples include payments to:

• Speed up the processing of permits or licences
• Expedite customs clearance
• Secure utility connections
• Obtain police protection

If you are asked to make a facilitation payment, you must refuse and report the request immediately.

Gifts and Hospitality

Gifts and hospitality can be legitimate business activities but can also be used as bribes. We have clear rules to ensure gifts and hospitality are appropriate.

General Principles

All gifts and hospitality must be:

• Legal and appropriate
• Reasonable and proportionate
• Given or received openly and transparently
• Not intended to influence a business decision
• Not given or received during a tender or procurement process
• Recorded in the gifts and hospitality register

Giving Gifts and Hospitality

Type	Permitted	Approval Required
Modest promotional items (pens, notepads, calendars)	Yes	No
Gifts up to £25 value	Yes	No
Gifts £25–£75 value	Case by case	Line manager
Gifts over £75 value	No	Not permitted
Working meals	Yes	No
Business entertainment up to £75 per head	Yes	Line manager
Business entertainment over £75 per head	Case by case	Director
Event hospitality (sports, concerts)	Case by case	Director
Travel or accommodation	No	Not permitted

Receiving Gifts and Hospitality

Type	Permitted	Action Required
Modest promotional items	Yes	None
Gifts up to £25 value	Yes	Record in register
Gifts £25–£75 value	Case by case	Approval and register
Gifts over £75 value	No	Politely decline or return
Working meals	Yes	None
Reasonable business entertainment	Yes	Record in register
Lavish entertainment	No	Politely decline
Travel or accommodation	No	Politely decline
Cash or cash equivalents	Never	Decline and report

Gifts and Hospitality Register

All gifts and hospitality over £25 in value (given or received) must be recorded in the gifts and hospitality register, including:

• Date
• Description
• Value (actual or estimated)
• Giver or recipient
• Business context
• Approval obtained

The register is reviewed regularly by senior management.

During Procurement

Extra caution is required during procurement processes:

• No gifts or hospitality should be given to or received from parties involved in a live tender
• Even modest hospitality should be avoided during evaluation periods
• Any approaches should be reported immediately

Dealing with Public Officials

Extra care must be taken when dealing with public officials, including:

• Government ministers and civil servants
• Local authority officers and councillors
• NHS and public sector employees
• Police and regulatory officials
• Foreign government officials

Rules for Public Officials

• Never offer gifts, hospitality, or payments to influence decisions
• Be aware that even modest hospitality may be prohibited by their employer
• Never offer employment or work experience to relatives as an inducement
• Document all interactions appropriately
• Report any requests for improper payments

Third Parties and Agents

We can be held liable for bribery committed by third parties acting on our behalf. We must ensure our agents, subcontractors, and business partners do not engage in bribery.

Due Diligence

Before engaging third parties who will act on our behalf, we conduct due diligence including:

• Background checks and references
• Verification of business legitimacy
• Assessment of bribery and corruption risk
• Review of their anti-bribery policies
• Evaluation of their reputation

Contractual Protections

Contracts with third parties include:

• Anti-bribery warranties and representations
• Requirement to comply with anti-bribery laws
• Commitment to our Supplier Code of Conduct
• Right to audit
• Termination rights for breach

Ongoing Monitoring

We monitor third party relationships through:

• Regular review of payments and invoices
• Periodic reassessment of risk
• Audits where appropriate
• Prompt investigation of concerns

Red Flags

Be alert to warning signs that may indicate bribery risk:

• Requests for unusual payment arrangements
• Payments to third countries or offshore accounts
• Requests for cash payments
• Unusually high commissions or fees
• Lack of transparency about services provided
• Reluctance to provide anti-bribery commitments
• Poor reputation or adverse media
• Connections to public officials
• Requests for “consulting” fees with unclear scope

Political and Charitable Contributions

Political Contributions

All Services 4U does not make contributions to political parties, political organisations, or individual politicians. This includes:

• Cash donations
• Gifts in kind
• Sponsorship
• Loans
• Use of company resources

Employees may make personal political contributions but must not claim reimbursement or use company time or resources.

Charitable Donations

Charitable donations may be made where they are:

• Legal and ethical
• Made to legitimate registered charities
• Not used as a substitute for bribery
• Approved in accordance with our procedures
• Transparent and properly documented

Donations must not be made to charities connected to clients or officials involved in procurement decisions where there could be any perception of impropriety.

Record Keeping

Accurate record keeping is essential to demonstrate compliance and detect potential bribery.

Requirements

We must:

• Maintain accurate financial records and accounts
• Record all payments and receipts correctly
• Retain supporting documentation for all transactions
• Never create false or misleading records
• Never use off-book accounts or funds
• Report any discrepancies or irregularities

Records to Maintain

• Gifts and hospitality register
• Due diligence records for third parties
• Contract documentation
• Payment records and invoices
• Approval documentation
• Training records
• Investigation records

Risk Assessment

We assess bribery and corruption risks across our business.

Risk Factors

Risk Area	Considerations
Countries	Operations in high-corruption countries
Sectors	Public sector contracts, regulated industries
Transactions	Large contracts, complex procurement
Third Parties	Agents, subcontractors, intermediaries
Business Activities	Tendering, licensing, permits
Hospitality	Entertainment, gifts, sponsorship

Our Risk Profile

Our primary bribery risks include:

• Relationships with public sector clients (local authorities, housing associations)
• Subcontractor and supplier relationships
• Tendering for public contracts
• Gifts and hospitality in client relationships
• Potential pressure from third parties

Mitigation

We mitigate these risks through:

• This policy and supporting procedures
• Training and awareness
• Due diligence on third parties
• Gifts and hospitality controls
• Approval processes
• Monitoring and auditing
• Reporting mechanisms

Reporting Concerns

We encourage anyone with concerns about bribery or corruption to report them.

How to Report

Concerns can be reported through:

• Your line manager
• Senior management
• The Compliance Manager
• Human Resources
• Our confidential whistleblowing hotline
• Email: whistleblowing@allservices4u.co.uk

Protection for Reporters

We are committed to protecting anyone who reports concerns in good faith:

• No retaliation or victimisation will be tolerated
• Reports can be made confidentially or anonymously
• All reports will be taken seriously and investigated
• The identity of reporters will be protected where possible

Whistleblowing

Our Whistleblowing Policy provides additional protection for those who raise concerns. Reports of suspected bribery are treated as protected disclosures under the Public Interest Disclosure Act 1998.

External Reporting

In some circumstances, you may wish to report concerns to external bodies:

• Serious Fraud Office — For serious or complex fraud and corruption
• National Crime Agency — For bribery involving organised crime
• Police — For criminal offences
• Protect (formerly Public Concern at Work) — For advice on whistleblowing

Investigation

All reports of suspected bribery will be investigated.

Investigation Process

1. Receipt — Concern received and logged
2. Assessment — Initial assessment of allegation
3. Investigation — Thorough and impartial investigation
4. Findings — Conclusions reached based on evidence
5. Action — Appropriate action taken
6. Closure — Matter closed and documented

Investigation Principles

• All investigations conducted fairly and impartially
• Confidentiality maintained as far as possible
• Evidence preserved and protected
• Legal advice sought where appropriate
• Relevant authorities notified if required

Consequences of Breach

Breaches of this policy are treated extremely seriously.

Internal Consequences

Employees who breach this policy may face:

• Disciplinary action up to and including dismissal
• Summary dismissal for gross misconduct
• Recovery of any losses caused
• Reporting to professional bodies

Third Party Consequences

Third parties who breach this policy may face:

• Termination of contract
• Exclusion from future work
• Recovery of any losses caused
• Reporting to relevant authorities

Legal Consequences

Individuals involved in bribery may face:

• Criminal prosecution
• Imprisonment (up to 10 years)
• Unlimited fines
• Director disqualification
• Confiscation of proceeds

Training

We provide training to ensure everyone understands their responsibilities.

Training Programme

Audience	Training	Frequency
All employees	Anti-bribery awareness	Induction + annual refresh
Managers and supervisors	Enhanced anti-bribery training	Induction + annual refresh
Procurement staff	Procurement-specific training	Induction + annual refresh
Client-facing staff	Gifts and hospitality training	Induction + annual refresh
Senior management	Leadership and accountability	Annual

Training Content

Training covers:

• What constitutes bribery and corruption
• The Bribery Act 2010 and offences
• This policy and procedures
• Gifts and hospitality rules
• Red flags and warning signs
• Reporting concerns
• Consequences of breach

Training Records

Training completion is recorded and monitored. All staff must complete anti-bribery training as a condition of employment.

Responsibilities

Board of Directors

• Overall accountability for anti-bribery compliance
• Setting the tone from the top
• Ensuring adequate resources and procedures
• Reviewing policy and performance

Managing Director

• Leadership commitment to zero tolerance
• Ensuring policy implementation
• Reviewing significant issues and investigations

Compliance Manager

• Day-to-day policy implementation
• Training coordination
• Maintaining registers and records
• Investigating concerns
• Reporting to senior management

Managers

• Ensuring team awareness and compliance
• Approving gifts and hospitality
• Identifying and escalating concerns
• Leading by example

All Employees

• Understanding and following this policy
• Reporting concerns
• Refusing to participate in bribery
• Completing required training

Monitoring and Review

We monitor compliance with this policy and review its effectiveness.

Monitoring

• Regular review of gifts and hospitality register
• Audit of third party due diligence
• Review of expense claims and payments
• Investigation of concerns and allegations
• Analysis of trends and patterns

Key Indicators

Indicator	Purpose
Training completion rate	Awareness and compliance
Gifts and hospitality registered	Policy compliance
Concerns reported	Reporting culture
Investigations conducted	Response effectiveness
Third party due diligence completed	Risk management

Policy Review

This policy is reviewed annually and updated as necessary to reflect:

• Changes in legislation
• Changes in our operations
• Best practice developments
• Investigation findings
• Audit recommendations

Related Policies

This policy should be read in conjunction with:

• Whistleblowing Policy
• Code of Conduct
• Supplier Code of Conduct
• Expenses Policy
• Procurement Policy
• Fraud Prevention Policy

Approval

This Anti-Bribery and Corruption Policy has been approved by the Board of Directors and is communicated to all employees, subcontractors, and relevant stakeholders.

Date: [Date]

Review Date: [Date + 1 year]

Contact

For questions about this policy or to report concerns:

Compliance Manager Email: compliance@allservices4u.co.uk Phone: [Phone number]

Confidential Whistleblowing Hotline Phone: [Hotline number] Email: whistleblowing@allservices4u.co.uk

Quick Reference Guide

Do

✓ Conduct business honestly and ethically

✓ Follow the gifts and hospitality rules

✓ Record gifts and hospitality in the register

✓ Report any concerns or suspicions

✓ Complete anti-bribery training

✓ Conduct due diligence on third parties

✓ Keep accurate records

Don’t

✗ Offer or accept bribes in any form .

✗ Make facilitation payments

✗ Give or receive excessive gifts or hospitality

✗ Use third parties to make improper payments

✗ Ignore warning signs or red flags

✗ Retaliate against those who report concerns

✗ Create false or misleading records

All Services 4U has zero tolerance for bribery and corruption. This policy is available to all interested parties on request.