Anti-Bribery

(Non-contractual policy. Statutory obligations under the Bribery Act 2010 apply regardless.)

Policy Statement

ACT Acoustics has a zero-tolerance approach to bribery and corruption. We will conduct our business honestly, ethically, and in compliance with the Bribery Act 2010.

Bribery is a criminal offence. Under the Bribery Act 2010, it is an offence to:

• Offer, promise, or give a bribe.
• Request, agree to receive, or accept a bribe.
• Bribe a foreign public official.

The company can also be prosecuted if it fails to prevent bribery by persons associated with it.

What This Means in Practice

You must not:

• Offer, promise, or give any payment, gift, or other advantage to any person with the intention of influencing them to act improperly.
• Accept any payment, gift, or other advantage that is intended to influence you to act improperly.
• Make facilitation payments (small unofficial payments to speed up routine processes) of any kind.

Gifts and Hospitality

Reasonable and proportionate hospitality — for example, a working lunch with a client or a modest Christmas gift — is a normal part of doing business and is generally acceptable. However:

• Never offer or accept gifts or hospitality where there is any suggestion that they are intended to influence a business decision.
• If you are offered a gift or hospitality worth more than £50, report it to Mike Wood.
• Use your common sense: if it would look wrong, it probably is wrong.

Reporting Concerns

If you suspect that bribery or corruption is taking place, report it immediately to Mike Wood or use the whistleblowing procedure.