Anti-Bribery & Corruption Policy for PlumbSpark Ltd

Document Classification: PUBLIC

Version: v1.0

Date Issued: 03/05/2023

Note: This document is uncontrolled when printed.

Introduction

At PlumbSpark Ltd, we are steadfastly committed to conducting all our business activities with utmost honesty and ethical integrity. We have adopted a strict zero-tolerance stance against bribery and corruption. Our commitment extends to acting in a professional, fair, and transparent manner in all our business interactions, wherever they may occur. To support this, we are dedicated to implementing and maintaining robust systems designed to effectively counteract bribery.

We are committed to upholding all applicable anti-bribery and corruption laws in every jurisdiction where we operate. This includes strict adherence to the UK Bribery Act 2010, ensuring our operations both domestically and internationally meet high ethical standards.

The principal objectives of this policy are to:

  • Clearly define the responsibilities of PlumbSpark Ltd and its employees in observing and upholding our position against bribery and corruption.

  • Provide comprehensive information and guidance to all employees on how to identify and handle issues related to bribery and corruption.

Bribery and corruption offenses carry severe consequences, including potential imprisonment for individuals and unlimited fines for companies. Such offenses can significantly harm our reputation and business operations. Therefore, we take these legal responsibilities with the utmost seriousness.

In this policy, the term "third party" includes any individual or organization you may interact with during the course of your work with PlumbSpark Ltd. This encompasses clients, suppliers, distributors, business contacts, as well as governmental bodies and their representatives.

Applicability of Policy

This policy is applicable to all individuals employed at every level within PlumbSpark Ltd, including but not limited to senior managers, officers, directors, full-time and part-time employees, consultants, contractors, trainees, remote workers, casual and agency staff, volunteers, interns, agents, and any other individuals associated with us or our subsidiaries.

Understanding Bribery

A bribe involves any inducement or reward offered, promised, or provided with the intention of gaining a commercial, contractual, regulatory, or personal advantage. Examples include:

  • Offering a Bribe: Providing incentives to secure business deals.

  • Receiving a Bribe: Accepting incentives to influence business decisions or actions.

  • Bribing a Foreign Official: Making payments to expedite processes or secure favourable treatment.

Guidelines on Gifts and Hospitality

While this policy does not prohibit customary and appropriate hospitality exchanged with third parties, it is imperative that such gestures comply with specific criteria to ensure they are not perceived as bribes. All gifts and hospitality must be transparent and justifiable.

Prohibited Conduct

It is unacceptable for any individual to engage in giving, promising, or accepting payments, gifts, or hospitality intended to secure or reward favourable treatment or a business advantage.

Stance on Facilitation Payments and Kickbacks

PlumbSpark Ltd unequivocally prohibits the acceptance or offering of facilitation payments and kickbacks. Employees must be vigilant and seek guidance if they encounter any requests for such payments.

Policy on Donations

PlumbSpark Ltd may make donations, but these must be legal, ethical, and approved by the compliance manager. All political contributions are made transparently and publicly disclosed.

Employee Responsibilities

Every employee is expected to thoroughly read, understand, and comply with this policy. Any suspicions of bribery or corruption must be promptly reported to the appropriate authorities within the company.

Record Keeping Protocol

PlumbSpark Ltd maintains rigorous financial records and internal controls to support ethical business practices and transparency in all transactions.

Raising Concerns

Employees are encouraged to voice any concerns regarding potential bribery or corruption to their manager or the compliance manager, utilizing the procedures outlined in our Whistle Blowing Policy.

Guidance for Victims

If you find yourself a victim of bribery or suspect such activity, it is crucial to report the incident to the compliance manager without delay.

Protection for Whistleblowers

PlumbSpark Ltd assures protection for employees who reject bribery or report unethical practices, ensuring they face no adverse consequences for their actions.

Training and Communication

Comprehensive training on anti-bribery and anti-corruption practices forms an integral part of the onboarding process for new employees and is reinforced through ongoing training programs.

Policy Responsibility

The Board of Directors, alongside the compliance manager, bears the responsibility for the implementation and oversight of this policy, ensuring compliance with all legal and ethical obligations.

Monitoring and Review

The compliance manager is tasked with regularly reviewing this policy to ensure its continued effectiveness and relevance, implementing improvements as necessary.

Authorized by: Nilesh Ladva

Position: Compliance Officer

Date: 19/03/2025

Company: PlumbSpark Ltd