Anti-Bribery and Corruption Policy

1. Purpose

Avsec Resilience Ltd (“the Company”, “we”, “our”, “us”) is committed to conducting all of our business in an honest, transparent, and ethical manner. We operate a zero-tolerance approach to bribery and corruption and are committed to upholding all laws relevant to countering bribery and corruption, including the Bribery Act 2010.

The purpose of this policy is to:

  • Set out our responsibilities, and those of anyone working with or for us, in observing and upholding our zero-tolerance position on bribery and corruption.

  • Provide information and guidance on recognising and dealing with bribery and corruption issues.

2. Scope

This policy applies to:

  • All employees (permanent, temporary, part-time, or agency).

  • Directors, contractors, consultants, associates, and third-party representatives acting on behalf of Avsec Resilience Ltd.

  • Any other individuals or organisations engaged with us in a business capacity.

It applies to all business activities, whether conducted in the UK or internationally.

3. Definitions

  • Bribery: Offering, promising, giving, requesting, agreeing to receive, or accepting any financial or other advantage with the intention of inducing or rewarding the improper performance of a function or activity.

  • Corruption: The abuse of entrusted power for private gain, which may include bribery but also extends to fraud, nepotism, and misuse of position.

  • Facilitation Payments: Small, unofficial payments made to secure or speed up routine government actions. These are prohibited under this policy.

  • Gifts and Hospitality: Items of value, entertainment, or services offered in the context of business relationships. Legitimate, proportionate, and properly declared gifts or hospitality may be permitted, but must never be offered or accepted to gain a business advantage.

4. Policy Statement

  • We will not engage in bribery or corruption in any form.

  • We will not offer, give, request, or accept bribes under any circumstances.

  • Facilitation payments and “kickbacks” are strictly prohibited.

  • We will maintain accurate books, records, and financial reporting to demonstrate transparency.

  • Any employee or associated person who breaches this policy will face disciplinary action, which may include dismissal and potential legal proceedings.

5. Responsibilities

  • The Board of Directors has overall responsibility for ensuring this policy complies with legal and ethical standards.

  • Managers are responsible for implementing this policy within their teams and ensuring that staff understand and comply with it.

  • Employees and representatives must read, understand, and comply with this policy and report any suspected breaches.

6. Gifts and Hospitality

  • Occasional, proportionate, and reasonable hospitality or promotional expenditure may be acceptable, provided it is transparent and properly recorded.

  • Lavish, frequent, or secretive gifts or hospitality must never be offered or accepted.

  • All gifts or hospitality must be declared to management and recorded in the Gifts and Hospitality Register.

7. Risk Areas

Bribery and corruption risks may arise in the following areas:

  • Procurement and contract management.

  • Engagement with public officials and regulators.

  • International operations or third-party representatives.

  • Recruitment and awarding of training or consultancy opportunities.

Extra vigilance is required in these areas.

8. Reporting Concerns

  • Employees must report any concerns or suspicions of bribery or corruption immediately to their line manager or directly to the Managing Director.

  • Concerns may also be reported confidentially via email at: info@avsec-resilience.com.

  • We will not tolerate retaliation against anyone who raises a concern in good faith.

9. Training and Communication

  • All employees and relevant third parties will be made aware of this policy and provided with appropriate training where necessary.

  • This policy will be available on our website and internal systems.

  • Contracts with third parties will include clauses requiring compliance with anti-bribery and corruption standards.

10. Monitoring and Review

  • The Board will monitor the effectiveness of this policy and review it annually.

  • Internal audits may be conducted to ensure compliance.

  • Updates will be communicated to all staff and stakeholders as required.

11. Breaches of This Policy

  • Any employee found to have breached this policy will face disciplinary action, which may result in dismissal for gross misconduct.

  • We may terminate relationships with third parties, contractors, or associates who breach this policy.

  • Breaches may also result in criminal prosecution under the Bribery Act 2010.

Approved by: Stephen Ackroyd 
Date of approval: 01 September 2025
Review date: 01 September 2026