ANTI-CORRUPTION COMPLIANCE POLICY

Purpose

This Anti-Corruption Compliance Policy establishes the commitment of Techspire Consulting Limited to uphold the highest standards of integrity, transparency, and ethical conduct in all its business dealings. The policy aims to prevent bribery, corruption, and unethical practices in accordance with UK laws and regulations.

Scope

This policy applies to all employees, officers, directors, contractors, consultants, and third-party representatives of Techspire Consulting operating in the United Kingdom.

Prohibited Conduct

Bribery and Corruption

Employees and representatives must not offer, promise, give, solicit, or accept anything of value, directly or indirectly, to gain an improper business advantage.

Facilitation Payments

The company strictly prohibits facilitation payments or “grease payments” to expedite routine government actions.

Kickbacks and Gifts

No employee shall provide or receive kickbacks, gifts, entertainment, or hospitality that could improperly influence a business decision.

Conflicts of Interest

Employees must disclose any relationships or activities that could create a conflict between personal interests and the company’s business interests. Conflicts of interest may arise when employees, their family members, or close associates have a financial or personal interest in a transaction, vendor, or competitor of the company. Any situation that could compromise the employee’s ability to act in the best interests of the company must be declared and managed appropriately.

Conflict of Interest Reporting Process:

Employees must disclose potential conflicts of interest in writing to their direct supervisor or the Compliance Department as soon as they become aware of the conflict.
The Compliance Department will assess the reported conflict and determine appropriate mitigation measures, such as recusal from decision-making or reassigning duties.
If required, employees may be asked to provide additional documentation to support their disclosure.
The final decision regarding the conflict and its resolution will be communicated to the employee in writing.
All disclosed conflicts and corresponding actions will be recorded and maintained for compliance purposes.
Employees who fail to report a known conflict of interest may face disciplinary action.

Compliance with UK Laws and Regulations

All employees must comply with UK anti-corruption laws, including but not limited to:

The UK Bribery Act 2010
The Fraud Act 2006
The Proceeds of Crime Act 2002

Due Diligence

Techspire Consulting will conduct due diligence on third parties, including vendors, partners, and agents, to ensure compliance with UK anti-corruption laws. This due diligence process will include:

Risk Assessment – Identifying the level of corruption risk associated with each third party based on their location, industry, and prior history.
Background Checks – Conducting background investigations on third parties, including reviewing financial records, company structures, and any past legal or regulatory violations.
Contractual Safeguards – Incorporating anti-corruption clauses in all agreements with third parties, ensuring compliance with this policy and UK laws.
Ongoing Monitoring – Regularly reviewing third-party transactions and business relationships to identify potential red flags and compliance risks.
Reporting and Documentation – Maintaining detailed records of all due diligence activities to ensure transparency and accountability.

Reporting Violations

Employees are required to report any suspected violations of this policy through the company’s whistleblower channels. Reports may be made anonymously and without fear of retaliation.

Whistleblower Reporting Process:

Employees should report concerns via the designated whistleblower email address: [email protected]
Upon receiving a report, the Compliance Department will acknowledge receipt within five business days.
An initial assessment will be conducted to determine the severity and credibility of the concern.
If further investigation is required, an internal review or independent audit will be initiated.
Employees involved in the investigation may be interviewed, and relevant documentation will be reviewed.
Upon conclusion of the investigation, appropriate actions will be taken, which may include disciplinary measures, process improvements, or legal action if necessary.
The whistleblower will be informed of the outcome to the extent permitted by confidentiality and legal constraints.
All reports and investigations will be documented and stored securely to ensure compliance with legal and regulatory requirements.
Retaliation against whistleblowers is strictly prohibited, and any reported retaliation will be subject to disciplinary action.

Training and Awareness

Techspire Consulting is committed to ensuring that all employees understand and adhere to anti-corruption regulations. To reinforce ethical business practices, the company will implement a structured compliance training program:

Training Schedule:

Induction Training: All new employees will receive mandatory anti-corruption training as part of their onboarding process.
Annual Compliance Training: All employees must complete an annual refresher training session on anti-corruption policies and legal updates.
Role-Specific Training: Employees in high-risk roles (such as procurement, sales, finance, and executive management) will receive targeted training specific to their responsibilities.
Third-Party Training: Business partners, contractors, and relevant third parties will be provided with training materials or workshops to ensure compliance with the company’s anti-corruption policy.

Training Delivery:

Training will be conducted through a combination of online modules, in-person workshops, and interactive case studies.
Employees must complete training assessments to ensure understanding of anti-corruption principles and procedures.
Compliance training records will be maintained by the HR and Compliance Department for auditing purposes.

Monitoring and Updates:

The Compliance Department will regularly review and update training materials to reflect any changes in UK regulations or company policies.
Additional training sessions will be provided as needed in response to identified risks or compliance concerns.
Employees who fail to complete required training sessions may face disciplinary action.

Consequences of Violations

Violations of this policy may result in disciplinary action, including termination of employment and legal consequences, in accordance with UK laws.

Policy Review and Updates

This policy will be reviewed periodically and updated as necessary to ensure ongoing compliance with legal and regulatory changes in the UK.

Contact Information

For any questions regarding this policy, please contact the Compliance Department at [email protected].