Anti-Bribery & Anti-Corruption Policy

Contents

1. What does your policy cover?
2. Policy statement
3. Who is covered by the policy?
4. Definition of bribery
5. What is and what is not acceptable
   • Gifts and hospitality
   • Facilitation payments and kickbacks
   • Political contributions
   • Charitable contributions
6. Employee responsibilities
7. What happens if I need to raise a concern
   • How to raise a concern
   • What to do if you are a victim of bribery or corruption
   • Protection
8. Training and communication
9. Record keeping
10. Monitoring and reviewing

1. What does your policy cover?

1.1 This anti-bribery policy exists to set out the responsibilities of The Build Chain LTD and those who work for us regarding observing and upholding our zero-tolerance position on bribery and corruption.

1.2 It also exists to act as a source of information and guidance for those working for The Build Chain LTD. It helps them recognize and deal with bribery and corruption issues, as well as understand their responsibilities.

2. Policy statement

2.1 The Build Chain LTD is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. The Build Chain LTD has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever we operate.

2.2 The Build Chain LTD will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regard to our conduct both at home and abroad.

2.3 The Build Chain LTD recognizes that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

3. Who is covered by the policy?

3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.

3.2 In the context of this policy, a third-party refers to any individual or organization our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

3.3 Any arrangements our company makes with a third party are subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

4. Definition of bribery

4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage to induce or influence an action or decision.

4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage.

4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether directly, passively, or through a third party (such as an agent or distributor). They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.

5. What is and what is NOT acceptable

5.1 Gifts and hospitality

The Build Chain LTD accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets specific requirements:

• It is not made with the intention of influencing the party to obtain or reward the retention of a business or business advantage, or as an exchange for favors or benefits.
• It is not made with the suggestion that a return favor is expected.
• It is in compliance with local law.
• It is given in the name of the company, not in an individual’s name.
• It does not include cash or a cash equivalent (e.g., a voucher or gift certificate).
• It is appropriate for the circumstances (e.g., giving small gifts around Christmas or as a small thank you for a project).
• It is of an appropriate type and value and given at an appropriate time, considering the reason for the gift.
• It is given/received openly, not secretly.
• It is not selectively given to influence a key, influential person.
• It is not of excessive value (usually in excess of £100).
• It is not offered to, or accepted from, a government official or representative without prior approval.

5.3 Where it is inappropriate to decline the offer of a gift (e.g., when meeting with an individual of a certain culture who may take offense), the gift may be accepted but must be declared to the compliance manager.

5.4 The Build Chain LTD recognizes that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable will inevitably differ.

5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.

5.6 The intention behind a gift should always be considered. If there is any uncertainty, the compliance manager should be consulted.

5.2 Facilitation Payments and Kickbacks

The Build Chain LTD does not accept and will not make any form of facilitation payments. We recognize that facilitation payments are a form of bribery involving expediting or facilitating the performance of a public official for a routine governmental action.

5.8 The Build Chain LTD does not allow kickbacks to be made or accepted. Kickbacks are typically made in exchange for a business favor or advantage.

5.9 In situations where avoiding a facilitation payment may put personal security at risk, employees must:

• Keep any amount to the minimum.
• Ask for a receipt, detailing the amount and reason for the payment.
• Create a record concerning the payment.
• Report the incident to their line manager.

5.3 Political Contributions

The Build Chain LTD will not make donations to support any political parties or candidates. We recognize this may be perceived as an attempt to gain an improper business advantage.

5.4 Charitable Contributions

The Build Chain LTD accepts and encourages donations to charities through services, knowledge, time, or direct financial contributions. All charitable contributions must be disclosed and approved by the compliance manager to ensure they are legal and ethical under local laws.

6. Employee Responsibilities

6.1 Employees must ensure they read, understand, and comply with this policy, and with any training or anti-bribery information provided.

6.2 All employees are responsible for the prevention, detection, and reporting of bribery and corruption. They must avoid activities that could lead to a breach of this policy.

6.3 If an employee suspects bribery or corruption, they must notify the compliance manager.

6.4 Breaches of this policy will result in disciplinary action, which could include dismissal for gross misconduct. The Build Chain LTD reserves the right to terminate contractual relationships with employees if they breach this policy.

7. What happens if I need to raise a concern?

7.1 How to raise a concern

If you suspect bribery or corruption in relation to The Build Chain LTD, raise your concerns as early as possible. Speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal.

7.3 The Build Chain LTD will familiarize all employees with its whistleblowing procedures to ensure concerns can be raised swiftly and confidentially.

7.2 What to do if you are a victim of bribery or corruption

If you are offered a bribe, asked to make one, or suspect bribery, report it to the compliance manager immediately.

7.3 Protection

The Build Chain LTD will support anyone who refuses to accept or offer a bribe or raises a concern in good faith. We will ensure no one suffers detrimental treatment as a result of reporting bribery or corruption concerns.

Detrimental treatment includes dismissal, disciplinary action, threats, or unfavorable treatment related to the concern raised.

If you believe you have been subjected to unjust treatment, inform your line manager or the compliance manager immediately.

8. Training and communication

8.1 The Build Chain LTD will provide training on this policy during the induction process for new employees and regular training thereafter. Employees will be asked annually to formally accept that they will comply with this policy.

8.2 The anti-bribery and corruption policy will be communicated to all suppliers, contractors, business partners, and third parties at the outset of business relations.

8.3 Relevant training will be provided to employees to ensure compliance with the Bribery Act.

9. Record keeping

9.1 The Build Chain LTD will keep detailed and accurate financial records, and have appropriate internal controls in place. We will declare and keep a record of hospitality or gifts accepted and given, subject to managerial review.

10. Monitoring and reviewing

10.1 The compliance manager is responsible for monitoring the effectiveness of this policy and reviewing its implementation regularly.

10.2 Internal control systems and procedures will be audited regularly to ensure effectiveness in preventing bribery and corruption.

10.3 Employees are encouraged to offer feedback on this policy to the compliance manager.

10.4 This policy does not form part of an employee’s contract of employment and may be amended at any time to improve its effectiveness.