Anti-Bribery & Anti-Corruption Policy

1. What this policy covers

This policy sets out the responsibilities of The Campus Label LTD and everyone who works with or for us in observing and upholding our zero-tolerance position on bribery and corruption. It also acts as a source of information and guidance for recognising and dealing with bribery and corruption.

2. Policy statement

The Campus Label LTD is committed to conducting business in an ethical and honest manner. We have zero tolerance for bribery and corrupt activities and act professionally, fairly and with integrity in all dealings and relationships.

We uphold all laws relating to anti-bribery and corruption in every jurisdiction in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in our conduct both at home and abroad.

Bribery and corruption are punishable by up to ten years’ imprisonment and a fine. If our company is found to have taken part in corrupt activities, we may be subjected to an unlimited fine, excluded from tendering for public contracts, and face serious reputational damage. We take our legal responsibilities seriously.

3. Who is covered by this policy

This policy applies to all employees (whether temporary, fixed-term or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors and any other person associated with us (including third parties), wherever they are located. It also applies to officers, directors and board members at any level.

“Third party” means any individual or organisation we meet and work with: clients, customers, suppliers, distributors, business contacts, agents, advisers, government and public bodies, including their advisers, representatives, officials, politicians and public parties.

Any arrangement we make with a third party is subject to clear contractual terms, including specific provisions requiring the third party to comply with minimum anti-bribery and corruption standards.

4. Definition of bribery

Bribery is the act of offering, giving, promising, asking, agreeing, receiving, accepting or soliciting something of value or an advantage so as to induce or influence an action or decision.

A bribe is any inducement, reward or item of value offered to another individual in order to gain commercial, contractual, regulatory or personal advantage. Bribery is not limited to offering a bribe — accepting one is equally illegal.

Employees must not engage in any form of bribery, whether directly, passively, or through a third party. They must not bribe a foreign public official anywhere in the world. If uncertain whether something constitutes a bribe versus a gift or hospitality, employees must seek advice from the compliance manager.

5. What is and is not acceptable

5.1 Gifts and hospitality

The Campus Label LTD accepts normal and appropriate gestures of hospitality and goodwill (whether given to or received from third parties) provided they meet all of the following:

• Not made with the intention of influencing the other party.
• Not made with the suggestion that a return favour is expected.
• In compliance with local law.
• Given in the name of the company, not in an individual’s name.
• Does not include cash or cash equivalents (e.g. vouchers, gift certificates).
• Appropriate for the circumstances and given at an appropriate time.
• Of an appropriate type and value.
• Given or received openly, not secretly.
• Not selectively given to a key, influential person with the intention of directly influencing them.
• Not above an excessive value as pre-determined by the compliance manager (usually in excess of £100).
• Not offered to or accepted from a government official, representative, politician or political party without prior approval from the compliance manager.

Where it is inappropriate to decline an offer (for example, when meeting an individual of a culture or religion who may take offence), the gift may be accepted provided it is declared to the compliance manager. As good practice, gifts given and received should always be disclosed. Gifts from suppliers should always be disclosed.

5.2 Facilitation payments and kickbacks

The Campus Label LTD does not make or accept facilitation payments of any kind. We recognise these as a form of bribery that expedites a public official’s routine performance. We also do not allow kickbacks, which are typically made in exchange for a business favour or advantage.

Where avoiding such a payment may put an employee’s personal security at risk, they must keep the amount to a minimum, request a receipt detailing the amount and reason, create a record, and report the incident to their line manager immediately.

5.3 Political contributions

The Campus Label LTD will not make donations, in cash, in kind or otherwise, to support any political party or candidate. We recognise such donations could be perceived as an attempt to gain improper business advantage.

5.4 Charitable contributions

We accept and encourage charitable donations — whether services, knowledge, time or financial contributions — and disclose all such contributions we make. Employees must ensure that charitable contributions are not used to facilitate or conceal acts of bribery. All charitable donations must be legal and ethical under local laws and require approval from the compliance manager.

6. Employee responsibilities

Everyone working with or for The Campus Label LTD must read, understand and comply with this policy and with any related training or anti-bribery and corruption information provided. All are equally responsible for prevention, detection and reporting of bribery and corruption, and must avoid any activity that could lead to or imply a breach of this policy.

If you have reason to believe or suspect that bribery or corruption has occurred or is about to occur, you must notify the compliance manager. A breach of this policy may result in disciplinary action up to and including dismissal for gross misconduct.

7. Raising a concern

7.1 How to raise a concern

If you suspect bribery or corruption in relation to The Campus Label LTD, raise your concerns as early as possible. Speak to your line manager, the compliance manager, or a director. We will familiarise all team members with our whistleblowing procedures so concerns can be raised swiftly and confidentially.

7.2 If you are a victim of bribery or corruption

Tell the compliance manager as soon as possible if you are offered a bribe, asked to make one, suspect you may be bribed in the near future, or believe you are a victim of any corrupt activity.

7.3 Protection

We will support anyone who raises concerns in good faith under this policy, even if investigation finds they were mistaken. No one will suffer detrimental treatment (dismissal, disciplinary action, threats, or unfavourable treatment) as a result of refusing to accept or offer a bribe, or for reporting a concern. If you believe you have been treated unjustly, inform your line manager or the compliance manager immediately.

8. Training and communication

We provide training on this policy as part of the induction process for all new joiners. Team members receive regular relevant training on how to adhere to the policy and confirm annually that they will comply with it. Our zero-tolerance attitude is communicated clearly to all suppliers, contractors, business partners and third parties at the outset of business relations.

9. Record keeping

We keep detailed and accurate financial records with appropriate internal controls. We declare and keep a written record of the amount and reason for any hospitality or gifts accepted and given. Gifts and acts of hospitality are subject to managerial review.

10. Monitoring and reviewing

Our compliance manager is responsible for monitoring the effectiveness of this policy and reviewing its implementation regularly. Internal controls designed to prevent bribery and corruption are subject to regular audit. Improvements are applied as soon as possible. Feedback should be addressed to the compliance manager.

This policy does not form part of an employee’s contract of employment and The Campus Label LTD may amend it at any time to improve its effectiveness.