ANTI-CORRUPTION AND BRIBERY POLICY
Updated: June 2026
1. About this policy
XYZ will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the “Act”), which applies to conduct both in the UK and abroad.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.
This policy does not form part of any employee’s contract of employment. It will be reviewed regularly and may be amended from time to time.
2. Scope
This policy applies to all persons working for XYZ or on XYZ’s behalf worldwide in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, temporary staff, intermediaries, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
3. Policy Statement
XYZ Reality Limited (“XYZ”) seeks to conduct all of its business in an honest and ethical manner. XYZ takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly, and with integrity in all of its business dealings and relationships.
Bribery in any form is strictly prohibited, whether involving public officials, private individuals, or third parties.
4. Guiding Principles
To promote compliance internally, XYZ maintains:
- Proportionate procedures to keep accurate and complete financial records, including approval processes for payments and controls to prevent off-book transactions;
- Top-level commitment to ensuring this policy is enforced;
- Global risk assessment across geographies, sectors, transaction types, and internal controls implemented to prohibit bribery;
- Due diligence before onboarding new customers and suppliers, and ongoing monitoring of these relationships;
- Communication with employees, including onboarding and annual anti-bribery training (completion is recorded as evidence of compliance, with enhanced training for those in at-risk roles); and
- Ongoing monitoring and review of our procedures and this policy.
5. Policy Detail
5.1 What Is Bribery?
A bribe means a financial, charitable, or political donation, or other inducement or reward, for an action which is unethical, a breach of trust, improper in any way, or illegal. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract, or any other advantage or benefit. Bribery includes offering, promising, giving, accepting, or seeking a bribe.
The Bribery Act contains five key offences, each broadly defined:
- Active bribery (offering or giving a bribe to another) — an advantage offered to get the recipient to act improperly in the discharge of their functions;
- Passive bribery (accepting or requesting a bribe);
- Bribery of a foreign (non-UK) public official — an advantage intended to influence a public official to help your business in any way;
- Bribery by the body corporate where a senior officer consented or connived, creating personal criminal liability for directors and senior officers; and
- Failure by a commercial organisation to prevent bribery on its behalf by associated persons.
Please note: bribery-related payments may also constitute money laundering offences under the Proceeds of Crime Act 2002 (POCA).
A bribery offence is triggered when a person “associated” with the company pays a bribe to obtain business for the company, including third-party agents or distributors. XYZ can face criminal liability for the acts of associated persons even without knowledge or intent. Third-party due diligence and contractual protections such as anti-bribery clauses are therefore crucial. Bribery of foreign public officials is a strict-liability offence where no corrupt intent need be proved; stricter standards and risk assessments apply to any dealings with government or state-owned entities.
If you are unsure whether a particular act constitutes bribery, please consult XYZ Legal via the ticketing request system at hub.xyzreality.com, or if urgent, via instant message or call.
Specific Prohibitions
You must not:
- give or offer any payment, gift, hospitality, or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
- accept any offer from a third party that you know or suspect is made with the expectation that XYZ will provide a business advantage; or
- give or offer any payment (a “facilitation payment”) to a government official in any country to facilitate or speed up a routine or necessary procedure.
You must not threaten or retaliate against another person who has refused to offer or accept a bribe, or who has raised concerns about possible bribery or corruption.
5.2 Gifts and Hospitality
The Gifts and Hospitality Policy outlines a threshold of £50 and above, which requires manager written approval and an entry on the Gift Register managed by the HR team. See the Gifts and Hospitality Policy for full details.
5.3 Record-Keeping
You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expense claims relating to hospitality, gifts, or payments to third parties in accordance with our expenses policy and record the reason for the expenditure.
All accounts, invoices, and other records relating to dealings with third parties, including suppliers and customers, must be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
5.4 How to Raise a Concern
If you are offered a bribe, are asked to make one, or suspect that any bribery, corruption, or other breach of this policy has occurred or may occur, you must notify your manager, the VP of HR, or the VP of Legal as soon as possible. Reports can be made confidentially through the whistleblowing email alias confidential@xyzreality.com. See the Whistleblowing Policy for details of how reports are handled and investigated. No individual will suffer retaliation for raising genuine concerns.
6. Responsibilities
Legal Team (Policy Owner)
Owns this policy, reviews it annually, provides guidance on bribery and corruption questions, and oversees third-party due diligence and contractual protections.
All Staff and Associated Persons
Must read, understand, and comply with this policy; avoid any conduct that could constitute bribery; and report concerns promptly.
Managers, VP of HR and VP of Legal
Receive and escalate concerns, ensure their teams are trained and compliant, and maintain the records required by this policy.
The Board
Provides top-level commitment to a zero-tolerance approach and approves this policy.
7. Non-Compliance
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect. Bribery may also expose individuals and the company to criminal liability under the Bribery Act 2010 and related legislation.
8. Exceptions
There are no exceptions to the prohibition on bribery and corruption. No facilitation payments are permitted. Where you are uncertain whether a proposed action is permissible, you must seek guidance from XYZ Legal before proceeding.
9. Related Policies & Documents
This policy should be read in conjunction with:
- Gifts and Hospitality Policy
This policy has been approved by the Board of XYZ Reality Limited. Staff are required to acknowledge that they have received, read, understood, and agree to comply with this policy.
