Anti-Bribery & Corruption Policy

Last Updated: 3 October 2025

1. Policy Statement

Antony Bailey DevOps Consulting is committed to conducting business with honesty and integrity. We have a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships.

2. Purpose and Scope

This policy applies to all business activities and sets out our responsibilities in observing and upholding our position on bribery and corruption. It also provides information and guidance on how to recognise and deal with bribery and corruption issues.

3. Legal Framework

This policy aligns with:

• The UK Bribery Act 2010
• The US Foreign Corrupt Practices Act (FCPA)
• EU Anti-Corruption Directives
• International anti-corruption standards

4. Definition of Bribery and Corruption

4.1 Bribery

Bribery is offering, promising, giving, or accepting any financial or other advantage to induce or reward improper performance of a relevant function or activity.

4.2 Corruption

Corruption is the abuse of entrusted power for private gain, including acts of bribery, fraud, and other dishonest conduct.

5. Prohibited Activities

The following activities are strictly prohibited:

• Offering, promising, or giving bribes to any person
• Requesting, accepting, or receiving bribes from any person
• Facilitating or enabling bribery by third parties
• Failing to report known or suspected bribery
• Retaliating against those who report bribery concerns

6. Gifts and Hospitality

6.1 Acceptable Gifts and Hospitality

Modest gifts and hospitality may be acceptable if they:

• Are of nominal value (generally under £50)
• Are offered transparently and openly
• Are culturally appropriate and proportionate
• Cannot be perceived as an attempt to influence business decisions

6.2 Unacceptable Gifts and Hospitality

The following are never acceptable:

• Cash or cash equivalents
• Gifts or hospitality of significant value
• Anything offered in expectation of favourable treatment
• Gifts or hospitality that could compromise professional judgement

7. Third Party Relationships

When working with third parties, we will:

• Conduct appropriate due diligence
• Include anti-bribery clauses in contracts
• Monitor compliance with anti-bribery requirements
• Terminate relationships if bribery is suspected

8. Risk Assessment

We regularly assess bribery and corruption risks, considering:

• Countries and regions of operation
• Business partners and their practices
• Transaction types and complexity
• Level of government interaction

9. Training and Awareness

We are committed to:

• Providing anti-bribery training and guidance
• Ensuring awareness of legal requirements
• Regular updates on policy changes
• Clear communication of expectations

10. Reporting Concerns

If you suspect bribery or corruption:

• Report concerns immediately through our contact form
• You may report anonymously if preferred
• All reports will be investigated thoroughly
• We protect whistleblowers from retaliation

11. Investigation and Response

Upon receiving a report, we will:

• Conduct a prompt and thorough investigation
• Take appropriate remedial action
• Report to relevant authorities as required
• Implement measures to prevent recurrence

12. Consequences of Violations

Violations of this policy may result in:

• Termination of business relationships
• Legal action and prosecution
• Financial penalties and damages
• Reputational damage

13. Record Keeping

We maintain accurate records of:

• All gifts and hospitality given or received
• Due diligence on business partners
• Training provided and received
• Investigations and remedial actions

14. Policy Review

This policy is reviewed annually and updated as necessary to ensure continued effectiveness and compliance with evolving legal requirements.

15. Contact Information