Anti Corruption and Bribery Policy

ANTI-BRIBERY & CORRUPTION POLICY

1. Purpose

This Anti-Bribery & Corruption Policy outlines ShareForce’s commitment to conducting business with integrity and transparency. It establishes clear rules to prevent bribery, corruption, facilitation payments, and unethical conduct in all business dealings.

2. Scope

This policy applies to all ShareForce employees, officers, directors, contractors, consultants, suppliers, and any third parties acting on behalf of ShareForce.

3. Policy Statement

ShareForce has a zero-tolerance approach to bribery and corruption. Bribery is illegal under the UK Bribery Act 2010, and ShareForce is committed to full compliance. No employee or representative may offer, give, solicit, or receive bribes or improper inducements of any kind.

4. Definitions

  • Bribe: Anything of value offered to influence a business decision.
  • Corruption: Abuse of entrusted power for private gain.
  • Facilitation Payments: Small unofficial payments to secure routine actions—strictly prohibited.
  • Improper Advantage: Any benefit obtained through unethical influence.

5. Prohibited Conduct

Individuals must not:

  • Offer or accept bribes or kickbacks
  • Provide gifts or hospitality intended to influence a decision
  • Make facilitation payments
  • Manipulate procurement or bidding processes
  • Make political donations on behalf of ShareForce
  • Conceal or falsify financial records

6. Gifts & Hospitality

While ShareForce recognises that modest hospitality can support legitimate business relationships, the following rules apply:

  • Gifts or hospitality over £100 must be declared and recorded Cash or cash-equivalents are prohibited
  • Hospitality must be proportionate, infrequent, and not intended to influence decisions
  • Any offer that could create a sense of obligation must be refused

7. Third Parties & Suppliers

ShareForce may be held liable for bribery conducted by third parties. Therefore:

  • All suppliers must comply with ShareForce’s ethical standards High-risk partners may require enhanced due diligence Contracts must include anti-bribery compliance clauses

8. Record Keeping

All expenses, gifts, hospitality and third-party payments must be: Accurately recorded Supported by valid documentation Transparent and auditable

9. Reporting & Whistleblowing

Any concerns must be reported immediately to management or via the Whistleblowing Policy. Reports can be made confidentially and without fear of retaliation.

10. Consequences of Breaches Violations of this policy may result in:

  • Disciplinary action up to termination
  • Contract termination for third parties
  • Reporting to regulatory authorities
  • Civil or criminal penalties

11. Training & Awareness

ShareForce will provide training to ensure all employees understand bribery risks, reporting channels and legal obligations. 12. Review This policy will be reviewed annually to ensure continued compliance with legislation and best practice.

Review

This policy will be reviewed annually to ensure continued compliance with legislation and best practice.