Anti-Bribery Policy


1. Introduction

Acqius Ltd is committed to upholding the highest standards of integrity and ethical behaviour in all its business activities. We take a zero-tolerance approach to bribery and corruption and are dedicated to ensuring compliance with all applicable anti-bribery laws, including but not limited to the UK Bribery Act 2010.

This policy outlines Acqius Ltd's position on bribery and corruption and provides guidance to all employees, officers, agents, contractors, consultants, and any associated third parties. Compliance with this policy is mandatory, and failure to do so may result in disciplinary action or termination of contracts and/or employment.

2. Purpose

The purpose of this policy is to:

  • Ensure all Acqius Ltd stakeholders understand their responsibility to prevent, detect, and report any acts of bribery or corruption.
  • Protect Acqius Ltd from legal, financial, and reputational risks associated with bribery and corruption.
  • Promote transparency and accountability in all business transactions.

3. Scope

This policy applies to:

  • All employees, officers, and directors of Acqius Ltd, regardless of location.
  • Any third parties acting on behalf of Acqius Ltd, including agents, consultants, contractors, and suppliers.

4. Definitions

  • Bribery: Offering, promising, giving, accepting, or soliciting something of value as a means of influencing the actions of an individual in a position of power, typically to gain an improper advantage.

  • Corruption: Dishonest or fraudulent conduct by those in power, often involving bribery.

5. Policy Statement

Acqius Ltd prohibits all forms of bribery and corruption. We will not engage in or tolerate any activities that can be deemed as bribery, corruption, or unethical conduct.

6. Prohibited Activities

The following activities are prohibited under this policy:

  • Offering or receiving bribes: Direct or indirect payments, gifts, or offers of value made to influence or reward a decision.
  • Facilitating payments: Small, unofficial payments made to speed up routine actions or secure services.
  • Gifts and hospitality: While occasional gifts and hospitality may be acceptable, any exchange that might influence a business decision or is given with the intent to influence is strictly prohibited.
  • Political and charitable donations: All donations must comply with relevant legislation, and any donation intended to gain a business advantage is strictly forbidden.

7. Gifts and Hospitality

Gifts and hospitality can foster positive business relationships but must not be used to influence business decisions improperly. Employees should:

  • Seek management approval for gifts or hospitality valued over £100.
  • Report any received gifts or hospitality over £100.
  • Decline any gifts, offers, or entertainment that could be perceived as bribery or undue influence.

8. Responsibilities

  • Management: Responsible for implementing this policy, providing training, monitoring compliance, and investigating reports of bribery.
  • Employees: Must adhere to this policy, report any concerns, and avoid actions that may lead to bribery or corruption.
  • Third Parties: Expected to comply with Acqius Ltd's standards on anti-bribery, which may include contractual clauses enforcing adherence to this policy.

9. Reporting and Whistleblowing

Employees and third parties are encouraged to report any suspicions or concerns regarding bribery or corruption. Reports should be made confidentially to the Compliance Officer, and no one will suffer retaliation or repercussions for reporting in good faith.

10. Compliance and Record-Keeping

Acqius Ltd will maintain detailed and accurate records of all financial transactions and contractual arrangements. Record-keeping is essential to ensure transparency and accountability.

11. Breaches of Policy

Any employee found in breach of this policy may face disciplinary action, which could include termination of employment. For third parties, breaches may result in termination of contracts. Legal action may also be taken where applicable.

12. Training

Acqius Ltd will provide regular training on anti-bribery and corruption to all employees and relevant third parties to ensure awareness and understanding of their responsibilities under this policy.

13. Review and Monitoring

This policy will be reviewed annually and updated as necessary to reflect changes in legislation and best practice. Compliance with this policy will be monitored on an ongoing basis.

Policy Approval

Date of Approval: Nov 2023