1. Purpose

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To ensure the Company operates with integrity and in compliance with applicable anti-bribery laws.

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2. Scope

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Applies to all employees, contractors, and representatives.

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3. Zero-Tolerance Approach

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The Company adopts a zero-tolerance approach to bribery and corruption.

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4. Prohibited Conduct

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The following are strictly prohibited:

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• Offering, giving, or receiving bribes

• Improper payments or incentives

• Any activity that could be perceived as unethical or corrupt

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5. Gifts and Hospitality

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Any gifts or hospitality must be reasonable, proportionate, and not intended to influence decisions.

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6. Reporting Concerns

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Any concerns regarding unethical conduct should be reported promptly.

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7. Compliance

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The Company complies with the UK Bribery Act 2010.

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8. Limitation & Hierarchy

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This policy shall be read alongside the Company’s Terms & Conditions. In the event of conflict, the Terms & Conditions shall prevail.