Anti-Bribery & Corruption Policy

Zero Tolerance for Bribery and Corruption

All Services 4U is committed to conducting business ethically, honestly, and with integrity. We have zero tolerance for bribery and corruption in any form. We are committed to complying with all applicable anti-bribery and anti-corruption laws, including the Bribery Act 2010, and to acting professionally, fairly, and with integrity in all our business dealings and relationships.

This policy applies to all employees, directors, officers, agency workers, contractors, subcontractors, consultants, agents, and any other persons associated with All Services 4U.

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:

Organisations can face:

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:

Receiving bribes:

What is Not Bribery

Legitimate business activities are not bribery:

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

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:

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:

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:

The register is reviewed regularly by senior management.

During Procurement

Extra caution is required during procurement processes:

Dealing with Public Officials

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

Rules for Public Officials

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:

Contractual Protections

Contracts with third parties include:

Ongoing Monitoring

We monitor third party relationships through:

Red Flags

Be alert to warning signs that may indicate bribery risk:

Political and Charitable Contributions

Political Contributions

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

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:

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:

Records to Maintain

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:

Mitigation

We mitigate these risks through:

Reporting Concerns

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

How to Report

Concerns can be reported through:

Protection for Reporters

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

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:

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

Consequences of Breach

Breaches of this policy are treated extremely seriously.

Internal Consequences

Employees who breach this policy may face:

Third Party Consequences

Third parties who breach this policy may face:

Legal Consequences

Individuals involved in bribery may face:

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:

Training Records

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

Responsibilities

Board of Directors

Managing Director

Compliance Manager

Managers

All Employees

Related Policies

Monitoring and Review

We monitor compliance with this policy and review its effectiveness.

Monitoring

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:

This policy should be read in conjunction with:

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.

All Service 4U Limited | Company Number: 07565878

All Service 4U Limited | Company Number: 07565878

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