Anti-Bribery & Anti-Corruption Policy

1. Our position

Because much of our work supports government-led programmes, the integrity of our dealings with ministries, agencies and officials is fundamental. We have zero tolerance for bribery and corruption and are committed to acting professionally, fairly and with integrity in all engagements.

2. What is prohibited

• Offering, promising, giving, requesting or accepting any bribe — a financial or other advantage intended to influence a person’s actions improperly.
• Facilitation payments (“grease” payments) to secure or speed up routine official action.
• Using third parties, agents or intermediaries to do anything that would breach this policy.
• Soliciting or accepting kickbacks in connection with the award or delivery of any project.

3. Gifts and hospitality

Reasonable and proportionate gifts or hospitality may be acceptable where they are transparent, not intended to influence a decision, and lawful. Anything of more than modest value, or any gift or hospitality involving a public official, must be approved in advance and recorded.

4. Donations and political contributions

The Company does not make political contributions. Charitable donations are permitted only where lawful, transparent and not used as a route to improper advantage.

5. Due diligence on partners

We assess the integrity of partners, agents and counterparties, and include anti-bribery obligations in our agreements. We will decline or exit relationships that present unacceptable corruption risk.

6. Reporting and protection

Anyone who suspects bribery or corruption must report it to the Business & Legal Team. Reports may also be made to the Inspectorate of Government. Personnel who report genuine concerns in good faith are protected and will not suffer retaliation (see our Whistleblowing Policy).

7. Consequences

Breach of this policy is a serious matter that may lead to disciplinary action and, under the Anti-Corruption Act, criminal liability for individuals and the Company.