Anti Bribery Statement

1. Introduction

414 Technology Limited is committed to conducting all of its business in an honest and ethical manner. We take 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, wherever we operate.

This policy outlines the responsibilities of all employees and partners in upholding our stance against bribery and ensuring compliance with the UK Bribery Act 2010.

2. Purpose of Policy

The purpose of this policy is to:

Ensure compliance with the UK Bribery Act 2010.
Provide clear guidelines to employees on how to avoid involvement in bribery.
Protect the company from reputational damage, legal liability, and financial penalties.
Promote a culture of honesty and integrity.

3. Scope of Policy

This policy applies to all individuals working for or on behalf of 414 Technology at all levels and grades, including:

Employees (full-time, part-time, or temporary)
Contractors
Subcontractors
Consultants
Suppliers
Partners and agents

4. Definition of Bribery

Bribery is offering, promising, giving, or accepting any undue advantage or benefit (financial or otherwise) to influence the actions or decisions of an individual, company, or government body in a way that is improper, unethical, or illegal.

Under the UK Bribery Act 2010, there are four main offences:

Bribing another person (offering, promising, or giving a bribe).
Being bribed (requesting, agreeing to receive, or accepting a bribe).
Bribing a foreign public official (to gain business advantage).
Failure to prevent bribery (where a commercial organisation fails to prevent bribery committed by an associated person).

5. Prohibited Conduct

414 Technology prohibits:

Offering, giving, or accepting any form of bribe or kickback, whether in the form of money, gifts, hospitality, or any other benefit.
Making facilitation payments (small payments made to secure or speed up routine government actions).
Offering gifts or hospitality that could be interpreted as influencing business decisions.
Engaging in or tolerating any form of corruption, including through intermediaries such as agents, consultants, or third parties acting on behalf of the company.

6. Gifts and Hospitality

414 Technology recognises that the giving and receiving of gifts and hospitality can form part of building business relationships. However, these must:

Be reasonable, proportionate, and not intended to influence a business decision.
Be reported to the CEO if they exceed £500 or are of unusual value.
Not be offered during contract negotiations or competitive tender processes.

7. Responsibilities

All employees, contractors, and associates are required to:

Read, understand, and comply with this policy.
Avoid any activity that might lead to a breach of this policy or the appearance of improper behavior.
Report any suspected or actual bribery to the CEO

Managers must ensure that all employees are aware of the policy and regularly review business practices to ensure compliance.

If you believe or suspect that a violation of this policy has occurred or may occur, you are required to report it immediately. You can report concerns to:

CEO: Curtis Haynes; curtis@414tech.co.uk
Alternatively, use the company's whistleblowing procedure, ensuring anonymity if preferred.

All reports will be treated confidentially and investigated promptly.

8. Consequences of Non-Compliance

Violation of this policy by employees, contractors, or business partners can result in:

Disciplinary action, including termination of employment or contract.
Criminal prosecution, which may result in imprisonment or financial penalties for individuals and the company.
Reputational damage and potential loss of business opportunities.

9. Training and Communication

414 Technology will provide anti-bribery training to employees as part of the onboarding process and at regular intervals. Communication of this policy will be made clear in contracts and agreements with third parties and business partners.

10. Monitoring and Review

The Compliance Manager will monitor compliance with this policy and report regularly to the board of directors. The policy will be reviewed annually to ensure its effectiveness and compliance with changes in law.

11. Conclusion

Bribery is illegal, unethical, and damaging to the reputation of 414 Technology. All employees and partners must uphold the highest standards of integrity and comply with this policy to ensure that our business remains lawful and ethical.