Policy 10
Anti-Bribery & Corruption
“Winning work never justifies an improper payment, gift, favour or hidden arrangement.”
We prohibit bribery and corruption in any form, and we expect our suppliers and production partners to meet the same standard.
At a glance
The short version.
Zero tolerance
No bribes, kickbacks, secret commissions or facilitation payments.
Sensible hospitality
A coffee or modest thank-you is fine. Anything significant around a live tender or decision is discussed with a director first.
Declare conflicts
Personal, family or financial interests are disclosed so they can be managed openly.
In practice
What we commit to.
- Keep invoices, expenses and payments accurately described
- No off-book payments or deliberately vague invoices
- No political donations without director approval and legal review
- Never use charity or sponsorship to disguise a bribe
- Apply proportionate due diligence to agents and intermediaries
- Protect anyone who raises a genuine concern from retaliation
The detail
Everything else.
The key parts of the policy, in plain English. The downloadable PDF is the full, controlled version.
Risks relevant to us
Gifts during procurement, secret referral commissions, kickbacks through inflated invoices, personal benefits to influence client decisions, improper payments for permissions, undeclared conflicts and improper donations or sponsorship.
Personal safety first
If someone faces an immediate threat to their safety, safety comes first. Any payment made under duress is reported as soon as it’s safe.
Our six-principle approach
Proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.
Reporting and breaches
Concerns go to a Managing Director or through our Speak-Up policy. Breaches can lead to disciplinary action, ending engagements, recovering losses and referral to the authorities.
Review
Reviewed every year, and before entering higher-risk markets or relationships.
Laws and guidance this policy follows
- Bribery Act 2010
- Ministry of Justice Bribery Act 2010 guidance and its six principles
- Government Supplier Code of Conduct
The full document
Anti-Bribery & Corruption Policy
Version 1.0 · Effective October 2026 · Owner: Managing Directors
Questions about this policy?
If you’re concerned about something you’ve seen in a deal involving us, tell us in confidence.