Anti-Corruption and Bribery Policy

Coaley Peak Ltd is unequivocally committed to maintaining the highest standards of ethical conduct and integrity in all our operations, adopting a firm approach towards corruption and bribery in all their forms. This policy outlines our unwavering dedication to ensuring that all our business interactions are free from corruption and bribery.

Coaley Peak Ltd complies in full with the UK Bribery Act 2010 and all relevant international anti-corruption and anti-bribery legislation. We are unyielding in our dedication to eradicating any practices that contribute to corruption and bribery within our business operations and networks.

Coaley Peak Ltd recognises that facilitation payments, often considered as minor fees or bribes made to speed up routine processes, are considered illegal under UK law. Therefore, the giving of such payments is strictly prohibited.

Coaley Peak Ltd discourages the giving or receipt of any gifts under any circumstances. If any gifts are given or received, they must be promptly recorded in the gift register within 48 hours. All gifts or hospitality must be reasonable, proportionate, made in good faith, and compliant with all relevant laws. Any gift or act of hospitality that could be interpreted as a bribe is strictly prohibited.

Coaley Peak Ltd does not conduct or permit any political or charitable contributions.

We require all employees to disclose any potential or actual conflicts of interest, which can often lead to corruption. If a conflict of interest arises, it must be promptly reported to the management.

Coaley Peak Ltd requires all our suppliers and partners to annually report their compliance with our anti-corruption and bribery standards, as well as our broader commitment to ethical business practices. Any failure to abide by these standards or to provide an annual report could result in the termination of contracts or discontinuation of relationships with the respective entities.

We have established robust internal controls and audits designed to prevent and detect corrupt practices. These procedures are essential to ensure our business is conducted transparently and ethically.

We conduct due diligence checks on all third party suppliers before entering into any business relationship. These checks help us to assess and mitigate corruption and bribery risks.

We maintain accurate and transparent financial records, including a dedicated gift register, which helps to demonstrate our compliance with anti-bribery laws and this policy.

We equip our employees with training to aid them in identifying and reacting appropriately to potential incidents of corruption and bribery within our operations and supply chains. This encourages employees to voice their concerns or breaches fearlessly and without the threat of retaliation.

Coaley Peak Ltd is committed to ensuring that employees feel safe to report any misconduct. We provide a whistleblowing mechanism where employees can report any suspicions or evidence of corruption or bribery without fear of retaliation.

We urge all our employees, suppliers, and partners to report any suspicions or evidence of corruption or bribery. To report any concerns, please email [email protected] with 'Anti-Corruption & Bribery Report' in the subject line or send a recorded delivery letter to Coaley Peak Ltd, The Limes, Bayshill Road, Cheltenham, GL50 3AW, United Kingdom. All reports will be investigated promptly and thoroughly.

Non-compliance with this policy will not be tolerated and can lead to disciplinary actions, including termination, legal penalties, and other actions as per UK law.

Coaley Peak Ltd is committed to continuously improving our policies and practices to combat corruption and bribery. We will review and update this policy annually to ensure its continued relevance and effectiveness.

Coaley Peak Ltd is proud to stand against corruption and bribery. We are dedicated to maintaining the highest ethical standards in all our operations and partnerships, ensuring a better future for all. Your cooperation is integral to the success of this policy and to our commitment to ethical conduct and integrity.