Legal

Anti-Bribery and Corruption Policy

1. Introduction

StaffCircle Ltd is committed to conducting business with integrity, transparency, and accountability. We have a zero-tolerance approach to bribery and corruption in all forms and are dedicated to complying with the UK Bribery Act 2010 and all other relevant anti-corruption legislation. This policy applies to all employees, contractors, consultants, suppliers, and business partners working with or on behalf of StaffCircle Ltd.

2. Endorsement from Top Management

This policy is fully supported and endorsed by the senior management of StaffCircle Ltd, who are committed to fostering a culture of ethical business conduct and ensuring compliance at all levels of the organisation.

3. Key Commitments

3.1 Prohibition of Bribery and Corruption

StaffCircle Ltd strictly prohibits:

  • Offering, giving, soliciting, or receiving bribes in any form, including cash, gifts, hospitality, or favours, to gain business advantages.
  • Making facilitation payments (unofficial small payments to speed up routine actions) unless legally permitted and with prior approval.
  • Engaging in any form of corrupt activity, including kickbacks, conflicts of interest, or fraudulent conduct.

3.2 Gifts and Hospitality

While normal business hospitality is allowed, employees must ensure that any gifts, meals, or entertainment:

  • Are reasonable, proportionate, and not intended to influence business decisions.
  • Do not create a conflict of interest or breach company values.
  • Are transparently recorded and reported in accordance with company guidelines.

3.3 Third-Party Due Diligence

StaffCircle Ltd conducts due diligence when engaging third parties (e.g., suppliers, partners, and agents) to ensure they adhere to ethical business practices. We require our partners to comply with anti-bribery and corruption laws and reserve the right to terminate relationships where violations occur.

3.4 Compliance with Legislation

We are committed to complying with all relevant UK anti-bribery and corruption laws, including:

  • The UK Bribery Act 2010 – which criminalises both the giving and receiving of bribes, including bribery of foreign officials.
  • Any other applicable regulations governing financial transactions, procurement, and ethical business conduct.

3.5 Reporting and Whistleblowing

Employees and third parties are encouraged to report any suspected bribery or corruption without fear of retaliation. Reports can be made through:

  • A confidential whistleblowing mechanism.
  • Direct reporting to senior management or legal advisors.
  • Anonymously, where necessary, to ensure protection.

All reported concerns will be investigated promptly, and appropriate action will be taken, including disciplinary measures and legal reporting where required.

3.6 Training and Awareness

StaffCircle Ltd will provide regular training and guidance to employees on anti-bribery and corruption risks, including how to identify, prevent, and report misconduct.

4. Implementation and Review

This policy is reviewed annually and updated to reflect changes in legislation, business operations, and best practices. Compliance is monitored through regular risk assessments and internal audits.

By adopting this policy, StaffCircle Ltd reinforces its commitment to ethical business practices and maintaining the highest standards of integrity.

Signed:

Mark Seemann – CEO
Date: 14/03/2021

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