Anti- Bribery and Corruption policy

The purpose of this policy is to establish clear controls to ensure compliance with all applicable anti-bribery, corruption, tax evasion, and fraud-prevention legislation, and to ensure that the Company’s business is conducted in an honest, ethical and socially responsible manner.

This policy supports our wider ESG and Corporate Social Responsibility commitments and underpins our reputation for integrity.

- Zero tolerance: The Company takes a zero-tolerance approach to bribery, corruption, facilitation payments, tax evasion, and fraud.
- Compliance with law: We will uphold all relevant laws, including the UK Bribery Act 2010, the Criminal Finances Act 2017 (Corporate Criminal Offence of Failure to Prevent Tax Evasion), and the Economic Crime and Corporate Transparency Act 2023 (failure to prevent fraud).
- Consequences: Breaches may result in disciplinary action up to and including dismissal, termination of contracts, criminal liability, unlimited fines, exclusion from public tenders, and serious reputational damage.

This policy applies to:
- All employees, officers, directors, and consultants of The One Point Limited.
- Contractors, agency staff, interns, volunteers, and secondees.
- Subsidiaries, joint ventures, agents, distributors, and other third parties acting on behalf of the Company.

Third Party means any individual or organisation you come into contact with during the course of work, including clients, customers, suppliers, business partners, government officials, regulators, and politicians.

**4.1 Bribes**
Employees and associated persons must not offer, promise, give, solicit, or accept bribes, directly or indirectly.

**4.2 Gifts and Hospitality**
- Must be reasonable, proportionate, transparent, and for a legitimate business purpose.
- Thresholds: Gifts or hospitality exceeding £250 per instance, or £1,000 in aggregate per year, require written Director approval.
- Cash gifts are prohibited.
- All approved gifts/hospitality must be recorded in the Gifts & Hospitality Register.

**4.3 Facilitation Payments & Kickbacks**
Prohibited, except in cases of personal safety risks where minimal payments must be recorded and reported.

**4.4 Political Contributions**
No donations to political parties or candidates.

**4.5 Charitable Contributions**
Permitted, but must be legal, ethical, transparent, pre-approved, and recorded.

**4.6 Fraud and Tax Evasion**
Employees and third parties must not engage in or facilitate fraud or tax evasion.

- All employees must read, understand, and comply with this policy.
- Line managers must ensure their teams are aware and compliant.
- The Board of Directors has oversight.
- The Company Secretary is responsible for implementation, training, monitoring, and maintaining records.

- Maintain accurate books, records, and accounts.
- Keep written records of all gifts, hospitality, donations, and expenses.
- No “off-book” accounts or undocumented transactions.

- Employees are encouraged to raise concerns early.
- Concerns can be raised with a manager, the Company Secretary, or via the Confidential Whistleblowing Hotline.
- Reports will be investigated promptly and fairly.
- Retaliation against good faith reporting will not be tolerated.

- New employees receive training at induction.
- Annual refresher training will be provided.
- All staff must confirm annual compliance.
- The Company will communicate its zero-tolerance stance to suppliers, contractors, and partners.

- The Company Secretary reviews this policy annually or following legal changes.
- Regular audits and risk assessments will test effectiveness.
- Employees may suggest improvements at any time.

- Breaches by employees may result in dismissal.
- Breaches by contractors or third parties may result in contract termination.
- Serious breaches may be reported to regulators or law enforcement.