1) Policy statement

Integro has zero tolerance for bribery and corruption. We prohibit offering, giving, requesting, agreeing to receive, or accepting any bribe, kickback or improper advantage—directly or indirectly, in the UK or abroad. This includes facilitation payments and any improper advantage to public officials. Breaches may result in dismissal, contract termination and/or referral to authorities.

2) Scope & responsibilities

• Board: overall responsibility; sets tone, reviews effectiveness.
• Managers: implement controls, keep registers, escalate concerns.
• All personnel/partners: read, understand and comply with this policy and complete training.
  Questions or reports: info@integro.co.uk (confidential; no retaliation).

3) Gifts, hospitality & expenses

• Never offer/accept cash or cash equivalents (e.g., gift cards).
• Modest, proportionate hospitality that supports a legitimate business purpose may be acceptable.
• Pre-approval required for any gift/hospitality over £100 (or any offered to/from public officials).
• All gifts/hospitality must be recorded in the Gifts & Hospitality Register maintained by Compliance.
• Travel, accommodation or per-diems must be reasonable, business-related and never extended to family or friends.

4) Charitable donations & sponsorships

Permitted if transparent, properly recorded, not used as a channel to influence a decision, and approved in line with our delegated authorities. We do not make political donations without Board approval.

5) Third parties & procurement

• Conduct risk-based due diligence on agents, intermediaries, subcontractors and suppliers before engagement and periodically thereafter.
• Contracts must include anti-bribery clauses giving Integro the right to audit and to terminate for breach.
• Never use a third party to do what Integro is prohibited from doing.

6) Facilitation payments

All facilitation payments are prohibited. If you are pressured or concerned for personal safety, make the minimum payment necessary and report immediately to your manager and info@integro.co.uk.

7) Conflicts of interest

Declare any actual or perceived conflict (e.g., family, financial interests with a supplier/customer). Managers must record and manage conflicts.

8) Books, records & controls

Maintain accurate, complete and timely records. No “off-book” accounts. All payments must be supported by genuine invoices and approved per policy.

9) Training & communication

Mandatory anti-bribery training on induction and refreshed at least every two years (annually for higher-risk roles). Policy is available at https://www.integro.co.uk and issued to relevant third parties.

10) Reporting concerns (Speak Up)

Report suspected bribery or policy breaches to your manager or info@integro.co.uk. Reports are handled confidentially. Integro prohibits retaliation against anyone who raises a concern in good faith.

11) Monitoring & review

Compliance will monitor registers, incidents and controls and report to the Board annually. This policy is reviewed at least annually or following legal/operational changes.