Anti Fraud, Bribery & Corruption Policy

Wyatt Carruthers Jebb Ltd ("WCJ") is committed to conducting business with integrity, transparency, and accountability. This policy outlines our zero‑tolerance approach to fraud, bribery, and corruption and provides clear guidance for employees, partners, and stakeholders.

WCJ Policy Statement

WCJ prohibits:

• Offering, giving, requesting, or accepting bribes in any form.
• Engaging in corrupt acts, including misuse of authority, conflicts of interest, unlawful inducements, or facilitation payments.
• Any conduct that could be interpreted as attempting to influence public officials, in line with UK Finance guidance on defining public officials.

Permitted activities include proportionate, transparent, and properly recorded hospitality that aligns with WCJ’s internal guidelines and industry norms.

Our Commitment

At WCJ, we:

• Operate to the highest ethical standards.
• Promote honesty and professionalism across all areas of our business.
• Comply fully with UK legislation, including the Bribery Act 2010 and associated regulatory guidance.
• Take swift and decisive action against any form of fraud, bribery, or corruption.

What This Policy Covers

This policy applies to all WCJ employees, contractors, suppliers, agents, and anyone acting on our behalf. It covers:

• Bribery and corruption prevention
• Gifts and hospitality rules
• Conflicts of interest
• Due diligence with third parties
• Reporting concerns (whistleblowing)
• Investigation procedures

Understanding Bribery & Corruption

Bribery
Bribery is offering, giving, receiving, or requesting something of value to improperly influence a decision.

Corruption
Corruption is the abuse of entrusted power for personal or financial gain.

Facilitation Payments
These are strictly prohibited, even where culturally customary.

Fraud
Fraud involves deception intended to secure personal or financial gain.

Our Zero‑Tolerance Policy

WCJ forbids:

• Offering or accepting bribes of any kind
• Engaging in corrupt behaviours
• Attempting to influence public officials improperly
• Providing or receiving inappropriate gifts or hospitality

Reasonable, proportionate, and transparent hospitality may be permitted, but it must always be declared and approved.

Gifts, Hospitality & Expenses

We allow:

• Low‑value, infrequent gifts or hospitality when appropriate and transparent

We do not allow:

• Cash or equivalent gifts
• Excessive or repetitive hospitality
• Anything that could influence—or appear to influence—business decisions

All gifts above our internal threshold must be recorded in our Gratuities Register.

High‑Risk Areas

Public Officials
Interactions with public officials require extra caution and prior approval.

Third‑Party Relationships
We conduct due diligence to ensure suppliers, contractors, and partners meet our ethical standards.

Procurement
Supplier selection must always be fair, transparent, and based on merit.

Conflicts of Interest
Employees must declare any personal interest that could influence their work.

Charitable & Political Activities

• WCJ supports legitimate charitable giving following due diligence.
• WCJ does not fund political parties or activities and maintains strict political neutrality.

Employee Responsibilities

All employees must:

• Understand and follow this policy
• Report concerns immediately
• Refuse any improper payment or inducement

Failure to comply may result in disciplinary action.

Reporting Concerns (Whistleblowing)

If you suspect wrongdoing:

• Report it to your line manager or our Managing Director
• Use our internal whistleblowing channels

Reports are confidential, and retaliation is strictly prohibited.

Record‑Keeping

We maintain accurate, transparent financial and business records, including:

• A register of gifts and hospitality
• Documentation relating to audits and compliance

Training & Awareness

WCJ provides regular training to ensure all employees understand:

• How to identify bribery and corruption risks
• How to report concerns
• Their responsibilities under UK law

Monitoring & Compliance

Our Directors:

• Review the Gratuities Register regularly
• Conduct internal audits
• Update this policy as legislation or best practice evolves

Non‑compliance may result in termination of employment or legal action.

Investigation Procedures

When a concern is raised, WCJ follows a clear, structured process:

Step 1 - Initial Assessment
Reports are acknowledged and reviewed to determine severity and next steps.

Step 2 - Formal Investigation
A trained investigator (internal or external) collects evidence, interviews individuals, and prepares findings.

Step 3 - Interim Measures
Where needed, employees may be suspended on full pay or have access restricted.

Step 4 - Findings & Action
We take appropriate action, which may include disciplinary measures, dismissal, or referral to law enforcement.

Step 5 - Record Retention
All investigation records are securely stored in line with our data retention policies.

Consequences of Misconduct

Individuals may face:

• Disciplinary action
• Criminal prosecution
• Fines or imprisonment

WCJ may face:

• Unlimited fines
• Reputational damage
• Loss of contracts or tender opportunities

Policy Oversight

This policy is reviewed at least annually by WCJ’s Board of Directors.

Last updated: February 2026