Anti-Bribery Policy

1. Purpose

This policy outlines our approach to preventing bribery and improper influence in any form. We are committed to acting fairly, transparently, and in the best interests of the business at all times. Bribery and other forms of undue influence undermine trust and can result in poor commercial outcomes.

2. Scope

This policy applies to all employees, contractors, officers, and third parties acting on behalf of the business, regardless of role or location.

3. Key Risks to Our Business

In our industry, bribery and improper influence may not always be obvious. Specific risks include:

• Employees accepting bribes or kickbacks to sell assets at below-market value, prioritise certain buyers, or overlook due process
• Personal relationships or undisclosed interests that may affect decision-making
• Offering or receiving gifts or hospitality in a way that could appear to influence commercial decisions

These actions can damage our reputation, breach trust with clients, and result in legal consequences.

4. Our Position

We operate a zero-tolerance approach to bribery. All decisions—particularly around asset valuation, sale routes, and buyer engagement—must be made in the best interests of the business.
We do not prohibit low-value, reasonable gestures such as chocolates or small thank-you gifts. However, the following principles apply:

• Any gift or hospitality must be modest, infrequent, and never linked to a decision
• Anything over £50 in value must be declared and approved by a line manager
• Cash, gift cards, or personal commissions are never acceptable

If in doubt, ask your manager before accepting or offering anything.

5. Conflicts of Interest

You must declare any situation where personal interests could conflict with your responsibilities to the business. This includes:

• Ownership or involvement in another company
• Personal or family relationships with suppliers, clients, or buyers

Transparency protects both you and the business.

6. Reporting Concerns

If you become aware of any behaviour that may breach this policy—such as suspected bribery, favouritism, or inappropriate dealings—you should report it to your line manager or a director. All concerns will be handled sensitively and, where appropriate, confidentially.
We also support a whistleblowing framework, enabling employees to raise issues in good faith without fear of reprisal.

7. Consequences of Breach

Breaching this policy may lead to disciplinary action, including dismissal for serious misconduct. In some cases, it may result in legal action.

8. Review

This policy will be reviewed annually and updated if needed to ensure continued relevance and compliance with best practice and the Bribery Act 2010.