1. Purpose

This policy sets out our commitment to conducting business ethically, transparently, and in compliance with all applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010.

Bribery and corruption damage trust, distort markets, and expose the business and individuals to serious legal and reputational risk. They are not tolerated under any circumstances.

2. Scope

This policy applies to:

• All employees, directors, officers, and contractors
• Temporary staff, consultants, and agency workers
• Third parties acting on our behalf, including suppliers, partners, and intermediaries
• It applies to all business activities, in the UK and internationally.

3. Legal Framework

The UK Bribery Act 2010 creates four key offences:

• Bribing another person
• Being bribed
• Bribing a foreign public official
• Failure of a commercial organisation to prevent bribery

This policy is designed to meet the Act’s requirement for “adequate procedures” to prevent bribery.

4. Definition of Bribery

A bribe is an inducement, payment, reward, or advantage offered, promised, or given to influence a person’s actions improperly.

Bribes can be:

• Financial or non-financial
• Direct or indirect
• Given to or received from public officials or private individuals

Examples include:

• Cash payments or gifts
• Hospitality or entertainment intended to influence decisions
• Kickbacks, facilitation payments, or secret commissions
• Offers of employment or contracts in return for favourable treatment

5. Policy Statement

We operate a zero-tolerance approach to bribery and corruption.

You must not:

• Offer, give, request, or accept a bribe
• Make facilitation payments of any kind
• Use third parties to carry out bribery on your behalf
• Ignore or conceal suspected bribery

6. Gifts and Hospitality

Reasonable and proportionate hospitality or promotional activity may be acceptable if it:

• Is lawful
• Is infrequent and transparent
• Is not intended to influence a business decision
• Would not cause embarrassment if disclosed publicly

Gifts or hospitality must never:

• Be cash or cash equivalents
• Be excessive or lavish
• Be given during active procurement, tender, or negotiation processes

All gifts and hospitality must be recorded in accordance with internal procedures.

7. Facilitation Payments

Facilitation payments are small payments made to speed up routine government actions.

They are illegal under UK law and strictly prohibited, regardless of local custom or pressure.

8. Political and Charitable Contributions

Political donations must not be made on behalf of the business without explicit written approval from senior management.

Charitable donations must be genuine, transparent, and must not be used as a disguise for bribery.

9. Third Parties

We expect third parties to meet the same ethical standards as us.

Appropriate due diligence must be carried out before engaging third parties, particularly where:

• They represent us externally
• They operate in high-risk jurisdictions
• They interact with public officials on our behalf

Contracts should include anti-bribery clauses where appropriate.

10. Responsibilities

All individuals covered by this policy must:

• Read, understand, and comply with this policy
• Complete any required training
• Raise concerns where bribery or corruption is suspected

Managers are responsible for:

• Promoting compliance
• Assessing bribery risks in their areas
• Ensuring controls are followed

11. Reporting Concerns

Concerns about bribery or corruption should be reported immediately.

Reports can be made:

• To a line manager
• To senior management
• Via any confidential reporting or whistleblowing channel in place

Reports will be taken seriously and investigated promptly.

12. Protection for Whistleblowers

No individual will suffer retaliation, discrimination, or disadvantage for raising a genuine concern in good faith, even if it turns out to be unfounded.

13. Breaches of This Policy

Breaches may result in:

• Disciplinary action
• Termination of employment or contract
• Legal action
• Reporting to relevant authorities

14. Training and Awareness

Anti-bribery training will be provided where appropriate to ensure understanding of:

• Legal obligations
• Risk situations
• Reporting procedures

15. Monitoring and Review

This policy will be reviewed at least annually, and whenever there are:

• Changes in legislation
• Significant changes to business activities
• Identified control weaknesses

16. Approval

This policy is approved by the founder of Monofix limited and is effective from the date below.

Approved by: Dan Toms
Role: Founder 
Date: 17/12/2025

DOC-MF-ABPV2