Anti-Bribery Policy

Last reviewed: 19 November 2025 Version 19 November 2025

Scheduled review date To be reviewed annually or as required.

Purpose

1. The Group conducts its business to the highest legal and ethical standards. The Group
will not be party to corruption or bribery in any form. Such acts would damage the Group’s
reputation and expose the Group, and its employees and representatives, to the risk of
fines and imprisonment. The Group takes a zero-tolerance approach to bribery and
corruption by its employees and its third party representatives.
2. This policy sets out the steps you must take to prevent bribery and corruption, to comply
with applicable legislation and the Group’s requirements.
3. This procedure is non-contractual and does not form part of your contract of employment.
We reserve the right to vary it from time to time.
Scope
4. This procedure applies to all staff, including agency workers and staff on zero hours
contracts.

Anti-Bribery Objectives
5. The Group is committed to satisfy Anti-Bribery Management System requirements to ISO
37001:2016 standards. As part of our commitment to continual improvement, our system
provides a framework for setting, reviewing and achieving anti-bribery objectives
including:
a. To conduct business in accordance with defined ethical standards, including the
avoidance of bribery or other forms of corruption.
b. To comply with all applicable laws and regulations (including the Bribery Act 2010).
c. To maintain strong relationships with our business partners.

What is bribery and corruption?
6. A ‘bribe’ is any financial or other advantage offered, promised, requested or given to
induce a person to perform a relevant function or activity improperly, or to reward them
for doing so. In this context, a ‘financial or other advantage’ is likely to include cash or
cash equivalent, gifts, hospitality and entertainment, services, loans, preferential
treatment in a tendering process, discounts, etc.
7. ‘Bribery’ includes offering, promising, giving, accepting or seeking a bribe.
8. The timing of the bribe is irrelevant: payments made after the relevant event will still be
caught, as will bribes that are given or received unknowingly.
9. ‘Corruption’ is the misuse of office or power for private gain and it can be inter-related
with a conflict of interest.
10. All forms of bribery and corruption are strictly prohibited.
11. It does not matter whether the bribery occurs in the UK or abroad. A corrupt act
committed abroad may well result in a prosecution in the UK.
12. If you are unsure about whether a particular act constitutes bribery, you should raise it with your line manager.

Group Anti-Bribery Policy

Who can be involved in bribery?
13. Bribery and corruption can be committed by:
➢ the Group’s staff, managers or directors; and
➢ anyone who performs services for or on behalf of the Group, e.g. representatives,
suppliers and other third parties.

Prohibited acts
14. You must not:
a. give or offer any payment, gift, hospitality or other benefit in the expectation that a
business advantage will be received or in order to reward any business received;
b. accept any offer from a third party that you know or suspect is made with the
expectation that the Group will provide a business advantage for them or anyone
else; or
c. give or offer any payment to a government official in any country to facilitate or
speed up a routine or necessary procedure (sometimes known as a ‘facilitation
payment’).
15. No person must threaten or retaliate against another person for refusing to offer or accept
a bribe or for raising concerns about possible bribery or corruption.
Areas of specific risk
16. Certain areas of the business are at higher risk than others. These include:
a. Gifts, tips and hospitality. You must not solicit or accept any gift, tips or
hospitality in the course of your employment or otherwise from any third party who
may expect any company within the Group to provide them with a business
advantage. Nor must you give any gift or hospitality to any third party with a view
to expecting a business advantage for any company within the Group. The Group
does however exercise its discretion to permit the receipt of small, reasonable and
bona fide gifts, tips or hospitality and to the production and giving of genuine
marketing material provided they are below the thresholds set out below.

The Thresholds
• gifts above the value of £50.
• tips above the value of £20 and
• hospitality over the value of £100
• marketing material/merchandise above the value of £30

b. All gifts, tips, hospitality and marketing material/merchandise over the above
thresholds must be:
i. Declared and formally reported by you to the Regional
Director1 using the Bribery Prevention Declaration Form;
ii. authorised by the Regional Director1
; and
iii. recorded in a Gifts, Tips, Hospitality and Marketing register
by the Regional Director (or as otherwise delegated).
c. Conflicts of Interest: may occur where your interest in a particular matter is or
risks being at odds with the Group’s interests leading to decisions, actions,
activities or relationships that risk undermining the interests and/or integrity of the
Group.
Conflicts can be actual, potential or perceived and decisions can be tainted by
them. They can arise in numerous ways, including but not limited to the
1
or the Head of Legal (or as otherwise directed by the Head of Legal)
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following circumstances:
i. due to family (whether by blood, marriage or relationship) such as
recruiting or promoting relations and working together (including
supplying services to a family member), risks impartiality and/or
corroboration concerns. All family relationships with other staff or any
of our service users must be declared whether or not they present an
actual conflict of interest as there will always be the potential for a
conflict to arise if undeclared;
ii. as a result of your personal financial interests (or that of your family’s)
such as investments, setting up in competition with our business or
working for a competitor; and/or
iii. using company connections or resources such as IT equipment or
tools for your own private purposes
d. All staff must declare and seek authority from their Regional Director4
for any and
all potential, actual or perceived conflict of interest using the Conflicts & Interests
Declaration Form.
e. Third parties: The Group sometimes uses external parties to help it achieve its
business objectives, but this can involve significant risks. Anyone who deals with
third parties who act on the Group’s behalf must familiarise themselves with this
policy and adhere to its procedures.
f. Facilitation payments: These are small bribes paid to facilitate routine
Government action, e.g.: speeding up the grant of a licence or permit. Such
payments are illegal and the Group does not offer or pay them. If you are faced
with a request or demand for such a payment, you must contact the Legal
Department immediately.
g. Political contributions: Such contributions can be (or be seen as) bribes in
disguise. The Group does not make donations to political parties and you must
not make a donation which is stated to be on the Group’s behalf.
h. Donations to charities and non-profit organisations: Bribes may be disguised
as charitable donations. You must not make a donation to any charitable or notprofit organisation on behalf of the Group without the prior approval of the Group’s
CEO.
i. Public procurement: Such transactions give rise to a high risk of bribery. Bribery
might involve providing procurement staff or other officials with gifts, hospitality,
holidays or promises of future employment in exchange for favourable treatment.
Alternatively, an official may request a ‘kickback’ in which a portion of the value of
the contract is given as a bribe for services rendered, such as securing the
contract. You must not offer or pay any undue payment or other consideration in
order to obtain or retain business, or to secure any other improper advantage.
Records
17. Transparency is vital. Records are a useful means of proving conformity with relevant
procedures.
18. All staff must declare and properly record in writing all interests (including but not limited
to perceived, potential or actual conflicts of interest), gifts, tips, hospitality and marketing
given or received to their Operations Manager/Director1 as detailed above.
19. All accounts, invoices, credit notes, purchase orders and other records relating to dealing
with third parties (including suppliers and customers) must be properly prepared in
accordance with the Group’s prevailing practices and requirements and with accuracy
and completeness. No account may be kept ‘off book’.
Indicators of bribery and corruption
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20. Common indicators of bribery and corruption include those listed below. This is not an
exhaustive list and there may well be others.
a. Payments are for abnormal amounts or purposes, or made in an unusual way.
For example, what would normally be a single payment is made in stages, through
a bank account never previously used, or in a currency or via a country that has
no connection with the transaction.
b. Process is bypassed for approval or sign-off of terms, payments or other
commercial matters. Those whose job it is to monitor commercial processes may
be hindered from doing so.
c. Individuals are secretive about certain matters or relationships and/or insist on
dealing with particular customer or contacts personally. For example, the person
may make trips at short notice without explanation or have a more lavish lifestyle
than expected.
d. Decisions are taken without any clear rationale.
e. Records are incomplete or missing.
Your responsibility
21. You are responsible for:
a. reading and becoming aware of the contents of this policy, acknowledging and
complying with it;
b. completing all assigned training by the due date
c. reporting cases where you know or have a reasonable suspicion that bribery or
corruption has occurred or is likely to occur in the business.
d. Declaring any offers or acceptance of gifts, gratuities, hospitality or marketing
regardless of value.
Guidance for reporting bribery concerns
22. The Group encourages raising concerns of bribery or corruption in good faith, or on the
basis of a reasonable belief in confidence, without fear of reprisal.
23. If you discover or suspect that any bribery or corruption has occurred or may occur, you
must report it to your Operations Manager/Director (or as otherwise delegated) or the
Head of Legal for the Group (Anti-Bribery Compliance Manager) as soon as possible.
24. The Group has a Whistleblowing Policy to protect those that make a disclosure of
bribery or corruption in good faith from any detriment or dismissal and the Head of Legal
has authority and independence to investigate concerns and direct access to the Group
top management.
25. Although information may be provided anonymously, we encourage you to give your
name when reporting your concern whenever possible. This is because anonymous
disclosures are difficult to investigate. We nonetheless have a dedicated Ethics
Reporting Channel, Navex, to where anonymous reports may be made. Further details
are below.
26. If you have concerns about the conduct of any of these people then you should report it
to the Head of Legal (Email: lwengraf@clececare.co.uk).
Consequences of not complying with the anti-bribery policy
27. Any person who pays bribes on the Group’s behalf or otherwise breaches this policy may
face disciplinary action, which could result in your immediate dismissal for gross
misconduct.
28. Any non-employee who breaches this policy is liable to have their contract terminated
with immediate effect.
29. The criminal sanctions for committing a bribery offence are:
a. Any person guilty of bribery faces a substantial fine and/or up to 10 years’
imprisonment.
b. If an organisation is found guilty of bribery or even of failing to have adequate
procedures in place to prevent bribery, it will be subject to large fines.
Risk assessment and management
30. The risk of bribery and corruption in the Group’s business varies by area. The CEO and
Operations Directors (or as otherwise delegated), working with the Legal Department,
are responsible for assessing the level of risk to which business units are subject and
putting in place any measures additional to those outlined in this policy they consider are
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required.
31. The Group operates a Compliance Committee, comprising top management
representatives (CEO, Legal, Finance, Quality and Compliance), which meets quarterly to
review all Anti Bribery risks, controls, reports, initiatives and actions in response to activities
to ensure they are compliant with legal requirements, ISO 37001 (Anti Bribery)
requirements and Group expectations.
32. The Group works with external consultants, AVISO, to manage and meet the ISO 37001
Standards.
33. AVISO conduct annual Internal Audits and chair the Management Review and keep the
Group informed of any changes to Anti-Bribery legislation.
34. Annual financial audits are conducted by a third party and this process would identify any
anomalies or unusual activity.
35. All employees are required to complete annual Anti-Bribery training. E-learning is available
in the ACCESS Learning platform.
Responsibility for this policy
36. The CEO has overall responsibility for this policy. Operational Directors (or as otherwise
delegated) have responsibility for ensuring that the policy is adhered in their business
units.
37.The Operations Directors (or as otherwise delegated) are responsible for ensuring that
this policy is distributed and updated as required by law and will monitor, review and
evaluate this policy regularly to ensure compliance.
38. If you are in doubt about any aspect of this policy, do not hesitate to contact your
Operations Manager/Director.
Contacts

For Legal, Anti-bribery or Corruption:
Head of Legal
Luisa Wengraf
245 Hammersmith Road, London
W6 8PW
Email: lwengraf@clececare.co.uk
Ethics & Anonymous Whistleblowing

Reporting Channel
https://whistleblowersoftware.com/secure/commitment_clececareservices