Anti-Corruption and Bribery Policy

1. Introduction

C4C Group is committed to conducting business with integrity, transparency, and accountability. We have zero tolerance for corruption and bribery in any form. This policy outlines our commitment to preventing corruption and provides guidelines for our employees to recognize and avoid corrupt practices.

2. Purpose

The purpose of this policy is to:

• Promote ethical business practices.
• Ensure compliance with UK anti-corruption laws, including the Bribery Act 2010.
• Provide guidance to employees on recognizing and dealing with bribery and corruption.

3. Scope

This policy applies to all employees, directors, officers, and third parties acting on behalf of C4C Group, regardless of their location.

4. Definitions

• Bribery: Offering, giving, receiving, or soliciting something of value to influence a business decision.
• Corruption: Abuse of entrusted power for private gain.

5. Policy Guidelines

• Prohibition on Bribery and Corruption: Employees must not engage in any form of bribery or corruption.
• Gifts and Hospitality: Gifts and hospitality must be reasonable, proportionate, and not intended to influence a business decision.
• Facilitation Payments: Facilitation payments are prohibited unless a person’s safety is at risk.
• Donations and Sponsorships: All donations and sponsorships must be transparent and not intended to gain an improper business advantage.

6. Employee Responsibilities

• Training: Employees must participate in anti-corruption training provided by the company.
• Reporting: Employees must report any suspected bribery or corruption to their supervisor or the compliance officer.
• Compliance: Employees must comply with this policy and all applicable laws.

7. Training

C4C Group provides regular anti-corruption training to ensure employees understand the risks of bribery and corruption and how to avoid them. This training includes:

• Identifying and avoiding bribery and corruption.
• Understanding the legal consequences of engaging in corrupt practices.
• Procedures for reporting suspected corruption.

8. Monitoring and Review

The compliance officer will monitor the effectiveness of this policy and review it annually. Any necessary amendments will be made to ensure continued compliance with applicable laws.

9. Reporting and Whistleblowing

Employees are encouraged to report any concerns about bribery or corruption. Reports can be made confidentially to the compliance officer. Retaliation against employees who report in good faith is strictly prohibited.

10. Consequences of Non-Compliance

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment. Additionally, employees may face legal consequences under applicable anti-corruption laws.

11. Contact Information

For questions or further information regarding this policy, please contact the compliance officer at compliance@c4cgroup.co.uk.

12. Conclusion

C4C Group is dedicated to maintaining the highest standards of integrity and ethical conduct. By adhering to this policy, we ensure our business practices are free from corruption and bribery.