Anti-Corruption and Bribery Policy

1. Introduction

Coaley Peak Limited is committed to conducting business ethically and with integrity. This policy sets out our position on bribery and corruption and provides guidance to all employees, contractors, and third parties on expected standards of conduct.

2. Adherence to the UK Bribery Act 2010

Coaley Peak Limited complies fully with the UK Bribery Act 2010. Bribery is a criminal offence. We do not tolerate any form of bribery, whether direct or indirect, by or on behalf of our organisation. All personnel must understand and comply with this Act.

3. Facilitation Payments

Facilitation payments are strictly prohibited. These are unofficial payments made to secure or expedite routine or necessary actions. No employee or agent may make such payments on behalf of Coaley Peak Limited under any circumstances.

4. Gifts and Hospitality

All gifts and hospitality, whether given or received, must be recorded in the company gift register. Gifts and hospitality must be reasonable, proportionate, and given or received in good faith without any expectation of reciprocity. Any gifts above a nominal value must be approved by senior management.

4.1 Gift Policy

Coaley Peak Limited maintains a clear position on the giving and receiving of gifts and hospitality. The following rules apply to all employees, contractors, and anyone acting on behalf of the company:

• Nominal threshold — Gifts with a value exceeding £25 (or local equivalent) must be declared and approved by senior management before acceptance or offer.
• Gift register — All gifts given or received, regardless of value, must be recorded in the company gift register maintained by the compliance function.
• Prohibited gifts — Cash, cash equivalents (vouchers, gift cards), or gifts to public officials and government employees are strictly prohibited.
• Hospitality — Business hospitality must be proportionate, infrequent, and directly related to a legitimate business purpose. Lavish or frequent hospitality is not permitted.
• Reciprocity — No gift or hospitality may be offered or accepted where it could create an obligation, expectation of favourable treatment, or conflict of interest.
• Declining gifts — Employees should politely decline any gift or hospitality that does not meet these standards and report the offer to their line manager.
• Third parties — Suppliers, contractors, and business partners are expected to adhere to equivalent standards when interacting with Coaley Peak personnel.

Breaches of this gift policy are treated as breaches of the Anti-Corruption and Bribery Policy and may result in disciplinary action. For queries or to declare a gift, contact compliance@coaleypeak.co.uk.

5. Political and Charitable Contributions

Political donations or contributions are not permitted on behalf of Coaley Peak Limited. Charitable contributions must be transparent, properly documented, and approved by senior management to ensure they are not used as a vehicle for bribery.

6. Conflicts of Interest

All employees must disclose any personal interests that could conflict with the interests of Coaley Peak Limited. Conflicts of interest must be reported promptly and managed appropriately.

7. Supplier Scrutiny

We conduct due diligence on all suppliers, contractors, and business partners to assess bribery and corruption risks. Suppliers are expected to adhere to standards consistent with this policy.

8. Internal Controls

Coaley Peak Limited maintains robust internal controls including financial reporting, audit trails, and approval processes to prevent and detect bribery and corruption.

9. Third-Party Due Diligence

Before engaging third parties, we conduct risk-based due diligence to ensure they operate with integrity and do not pose a bribery or corruption risk to our organisation.

10. Record Keeping

We maintain accurate and complete records of all financial transactions. All accounts, invoices, and other documents must accurately reflect the transactions they represent.

11. Training

All employees receive training on anti-corruption and anti-bribery policies and procedures. Training is provided at induction and refreshed periodically. Records of training are maintained.

12. Whistleblowing

Coaley Peak Limited encourages the reporting of any concerns regarding bribery or corruption. We provide confidential reporting channels and protect whistleblowers from retaliation.

13. Reporting

Any suspected instances of bribery or corruption must be reported immediately to senior management. Reports can be made confidentially and will be investigated thoroughly.

14. Penalties

Breach of this policy may result in disciplinary action, including dismissal. Bribery is a criminal offence that can result in imprisonment and unlimited fines for both individuals and organisations.

15. Continuous Improvement

This policy is reviewed annually and updated as necessary to reflect changes in legislation, best practices, and organisational requirements. We are committed to the continuous improvement of our anti-corruption measures.