Bribery Policy

TBT Recruitment Ltd (“the Company”) is committed to conducting business fairly, transparently, and in compliance with the Bribery Act 2010 and all applicable anti-bribery and corruption laws.

We have a zero-tolerance approach to bribery and corruption. Any breach of this policy will be regarded as a serious matter and may result in disciplinary action, termination of employment, or the ending of business relationships.

This policy forms part of our wider approach to preventing corporate criminal offences and ensuring ethical business conduct across our operations and supply chain.

Who is Covered by this Policy

This policy applies to:

• All employees at every level (permanent, fixed-term, temporary, and agency).
• Directors, officers, consultants, and contractors.
• Suppliers, subcontractors, labour providers, and any other person or organisation acting on behalf of or representing the Company.

What is Bribery?

A bribe is any financial or other advantage offered, promised, given, requested or accepted with the intention of:

• Inducing or rewarding improper performance of a duty or function; or
• Influencing a public official in the performance of their duties.

Bribery can take many forms, including:

• Cash payments or gifts.
• Excessive or inappropriate hospitality or expenses.
• Kickbacks, facilitation payments, favours in exchange for business advantage.

Gifts, Hospitality, and Expenses

Normal appropriate business hospitality and low-value promotional gifts are permitted where they are:

• Reasonable, proportionate, and transparent.
• Not intended to influence or reward improper action.

Rules:

• All gifts or hospitality valued above £50 must be declared to and approved by a line manager.
• Cash gifts or vouchers are never permitted.
• Hospitality must not create an obligation or appear to influence decision-making.

Facilitation payments, kickbacks, and donations

• The Company strictly prohibits facilitation payments and kickbacks of any kind.
• We do not make contributions to political parties.
• Charitable donations must never be used as a means to secure a business advantage.

Responsibilities

• All employees and workers must read, understand, and comply with this policy.
• Managers must promote a culture of integrity, monitor compliance, and set the right example.
• The Company will provide training, carry out supplier due diligence, and enforce disciplinary or contractual action for breaches.

Raising concerns

Concerns about bribery or corruption must be reported immediately to a line manager or via the Company’s Whistleblowing Policy.

• All reports will be treated seriously and, where possible, confidentially.
• No employee will suffer and detriment for refusing to take part in bribery or for raising genuine concerns in good faith.

Monitoring and Review

The Company will:

• Monitor compliance with this policy.
• Conduct due diligence on suppliers and subcontractors.
• Review the policy annually (or earlier if legislation or best practice changes).

Related Policies

This policy should be read alongside the following Company policies:

• Slavery Policy
• Whistleblowing Policy

Review

This policy will be reviewed annually or sooner if there are significant changes in legislation, guidance, or business operations.

Reviewed August 2026 by Operations Director – Scott Jeffrey