Anti-Bribery and Corruption Policy
Last updated: 14 September 2025
Technophobia Ltd prohibits bribery and corrupt conduct in all dealings. We comply with the UK Bribery Act 2010. This policy applies to staff, contractors, and anyone acting for us.
1. Scope and definitions
- Bribe: an advantage offered, promised, given, requested, or received to influence a decision.
- Corruption: misuse of office for private gain.
- Applies to UK and overseas activities, public and private sector.
2. Core principles
- Zero tolerance for bribery, kickbacks, or improper influence.
- No offering or accepting anything that could affect impartiality.
- Use transparent processes for sales, tenders, and procurement.
3. Gifts, hospitality, and expenses
| Item | Rule |
|---|---|
| Modest hospitality | Allowed if reasonable, infrequent, business-related, and not during tenders. |
| Token gifts (£0–£50) | Permitted if branded/seasonal. Record if borderline. |
| Gifts £50–£150 | Director approval and log entry required. |
| Gifts >£150 | Decline or donate with the giver’s consent; log and notify a director. |
| Cash or cash-equivalents | Prohibited (vouchers, loans, crypto, bearer instruments). |
| Travel and accommodation | We pay our own. Third-party offers require director approval. |
- Never solicit gifts or hospitality.
- Refuse anything linked to a decision, quote, or award.
4. Facilitation payments
- Small “speed” payments to secure routine actions are illegal. Do not make them.
- If you feel at risk, prioritise personal safety, then report the incident at once.
5. Conflicts of interest
- Disclose personal relationships or interests that might affect decisions.
- Step back from related selections or approvals.
6. Third parties and due diligence
- Choose suppliers and partners on merit and fair terms.
- Use contracts that prohibit bribery and require lawful conduct.
- Heightened checks for agents, introducers, or anyone paid to influence decisions.
7. Records and approvals
- Keep accurate books and receipts. No off-book accounts.
- Record gifts/hospitality needing approval in the register kept by the director.
- Expenses must be honest, supported, and submitted promptly.
8. Political and charitable activity
- No political donations on behalf of the company.
- Charitable donations or sponsorships need director approval and a clear, legitimate purpose.
9. Reporting concerns
- Report suspicions immediately to a director at hello@technophobia.uk or by phone.
- We do not tolerate retaliation against anyone who raises a concern in good faith. See our Whistleblowing Policy.
10. Responsibilities and training
- Directors set and oversee this policy.
- All personnel must read this policy and follow it on every engagement.
- Brief training is provided at induction and refreshed when laws or risks change.
11. Breach and consequences
- Breaches may lead to contract action, dismissal from assignments, or referral to authorities.
- We will cooperate with lawful investigations.
12. Monitoring and review
- Annual review or after material incidents or legal changes.
- Updates are published on this page.
13. Contact
Technophobia Ltd · Company No. 14898332 · VAT GB 495 7043 58
13B Devonshire Road Industrial Estate, Millom, LA18 4JS, United Kingdom
+44 1229 774591 • hello@technophobia.uk