Anti-Bribery and Corruption Policy

Purpose

Genuine Way Limited is committed to conducting all aspects of its business with the highest levels of integrity and transparency. We have a zero-tolerance approach to bribery and corruption and are dedicated to complying with all applicable anti-bribery laws, including the UK Bribery Act 2010.

Scope

This policy applies to all employees, contractors, consultants, partners, agents, and any third party acting on behalf of Genuine Way Limited, regardless of location.

Policy Statement

  1. Prohibition of Bribery and Corruption
    • Genuine Way Limited strictly prohibits offering, giving, soliciting, or accepting any bribe or corrupt payment in any form, whether directly or indirectly.
    • Bribery includes offering or receiving money, gifts, favours, or anything of value to influence a decision, secure a business advantage, or gain improper benefits.
  2. Compliance with Laws
    • All employees and representatives must comply with applicable anti-bribery and corruption laws in the jurisdictions in which Genuine Way Limited operates.
    • Breaches of such laws could result in severe penalties, including criminal charges for individuals and significant fines for the company.
  3. Facilitation Payments
    • Facilitation payments (small payments to expedite routine government actions) are prohibited unless there is a genuine concern for personal safety or security. Any such payment must be reported immediately to management.
  4. Third-Party Relationships
    • All third-party relationships, including agents, suppliers, and partners, must undergo due diligence to ensure they adhere to the same anti-bribery standards as Genuine Way Limited
    • Agreements with third parties must include anti-bribery clauses to safeguard against improper conduct.
  5. Political Contributions
    • Genuine Way Limited does not make political donations or contributions of any kind.
    • Employees must refrain from using company funds or resources for political activities.
  6. Charitable Contributions
    • Charitable donations made on behalf of Genuine Way Limited must be transparent, documented, and aligned with the company’s values. They must not be used as a subterfuge for bribery.

Responsibilities

  1. Employees
    • Ensure personal compliance with this policy and promptly report any suspicions of bribery or corruption.
    • Avoid any activities that could bring Genuine Way Limited into disrepute.
  2. Management
    • Foster a culture of integrity and oversee adherence to this policy.
    • Ensure adequate training is provided to all employees regarding anti-bribery and corruption practices.
  3. Compliance Officer
    • Monitor and review the implementation of this policy and report any issues to senior management.
    • Maintain records of reported incidents and outcomes for accountability.

Reporting Concerns

  • Employees and third parties are encouraged to report any suspected bribery or corruption through Genuine Way Limited's confidential whistleblowing mechanism at legal@genuineway.co.uk.
  • All reports will be treated with the utmost confidentiality and investigated promptly.

Consequences of Non-Compliance

  • Employees or third parties found to have engaged in bribery or corruption will face disciplinary actions, up to and including termination of employment or contracts.
  • Genuine Way Limited reserves the right to report unlawful activities to relevant authorities.

Monitoring and Review

  • This policy will be reviewed annually to ensure it remains effective and aligned with current laws and business practices.

Last Updated: March 2025