Anti-Bribery Policy

Our commitment to preventing bribery and corruption

Policy Statement

Universal App Company has zero tolerance for bribery and corruption. We are committed to conducting business fairly, honestly, and transparently. This policy outlines our approach to preventing, detecting, and addressing bribery in compliance with the UK Bribery Act 2010 and other relevant legislation.

Scope

This policy applies to all employees, officers, directors, contractors, consultants, agents, and anyone acting on behalf of Universal App Company in the UK and abroad.

What is Bribery?

Bribery involves:

  • Offering a bribe: Offering, promising, or giving a financial or other advantage to induce or reward improper conduct
  • Receiving a bribe: Requesting, agreeing to receive, or accepting a financial or other advantage with the intention of performing functions improperly
  • Bribing a foreign public official: Offering or giving an advantage to a foreign public official to obtain or retain business or a business advantage
  • Failure to prevent bribery: An organization failing to prevent bribery by persons associated with it

Prohibited Conduct

The following are strictly prohibited:

  • Offering, promising, or giving bribes
  • Requesting, agreeing to receive, or accepting bribes
  • Making or receiving facilitation payments (small payments to secure or speed up routine actions)
  • Using third parties to make bribes on our behalf
  • Offering or accepting kickbacks
  • Political contributions intended to gain business advantage
  • Charitable donations used as a disguise for bribery

Gifts and Hospitality

Reasonable and proportionate gifts and hospitality are a normal part of business relationships. However, they must not:

  • Be given or received with the intention of influencing a business decision
  • Create a sense of obligation
  • Be excessive in value
  • Involve cash or cash equivalents
  • Be frequent or lavish

Guidelines for Gifts and Hospitality

  • Modest value: Gifts and hospitality should be of modest value (typically under £50)
  • Transparent: All gifts and hospitality must be recorded in our register
  • Approval: Gifts or hospitality above £50 require prior approval from management
  • Public officials: Extra caution is required with public officials; seek approval before offering or accepting any gifts or hospitality
  • Declined if inappropriate: If in doubt, decline and seek guidance

Responsibilities

All Personnel

Everyone must:

  • Comply with this policy at all times
  • Not engage in any form of bribery
  • Report any suspicions or actual instances of bribery
  • Complete anti-bribery training
  • Seek guidance when uncertain

Management

Managers must:

  • Lead by example
  • Ensure their teams understand and comply with this policy
  • Create an environment where concerns can be raised
  • Review and approve gifts and hospitality in their areas
  • Investigate reported concerns

Third Party Relationships

We conduct due diligence on third parties (suppliers, contractors, agents, intermediaries) to ensure they:

  • Understand and comply with our anti-bribery standards
  • Have their own adequate anti-bribery policies and procedures
  • Do not engage in bribery on our behalf

Contracts with third parties include anti-bribery clauses and the right to audit and terminate for non-compliance.

Public Sector Relationships

Extra care must be taken when dealing with public sector organizations and officials:

  • Follow all procurement rules and regulations
  • Do not offer anything that could be perceived as attempting to influence decisions
  • Be transparent about all interactions
  • Seek approval before offering any gifts, hospitality, or sponsorship

Record Keeping

We maintain accurate records of:

  • All gifts and hospitality given or received
  • Expenses claims
  • Contracts with third parties
  • Due diligence conducted
  • Training completed

Reporting Concerns

If you become aware of or suspect bribery or corruption, you must report it immediately through:

  • Your line manager
  • Human Resources
  • The compliance officer
  • Our confidential whistleblowing procedure

All reports will be treated seriously and investigated. You will be protected from retaliation for reporting genuine concerns in good faith.

Training and Awareness

We provide:

  • Regular anti-bribery training for all employees
  • Specific training for high-risk roles
  • Updates on policy changes and emerging risks
  • Guidance materials and resources

Consequences of Breach

Breaches of this policy are serious and may result in:

  • Disciplinary action, up to and including dismissal
  • Termination of contracts with third parties
  • Criminal prosecution (bribery is a criminal offence)
  • Substantial fines and imprisonment
  • Reputational damage

Monitoring and Review

We monitor the effectiveness of this policy through:

  • Regular risk assessments
  • Internal audits
  • Review of gifts and hospitality registers
  • Analysis of reported concerns
  • Annual policy review

When in Doubt

If you are unsure whether something constitutes bribery or is acceptable, ask yourself:

  • Would I be comfortable with this being made public?
  • Could this be perceived as an attempt to influence a decision?
  • Is this transparent and properly documented?
  • Would I be comfortable explaining this to my manager?

When in doubt, seek guidance before proceeding.

Last Updated: January 2024

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