Bribery and Corruption Policy

Bloomsbury Surveyors Bribery and Corruption Policy

1. Introduction

Bloomsbury Surveyors is committed to conducting business with integrity,
transparency, and in compliance with all applicable laws. This policy outlines the
company’s stance on preventing, identifying, and addressing bribery and corruption
in all its forms within the organisation and its business dealings.

2. Scope
This policy applies to all employees, whether permanent, temporary, or contract, as
well as consultants, contractors, agents, and any other individuals or entities acting
for or on behalf of the company.

3. Policy Statement
Bloomsbury Surveyors strictly prohibits:
Bribery: Offering, promising, giving, accepting, or seeking a bribe in any form,
whether cash or any other inducement, to or from any person or company to gain
commercial, contractual, regulatory, or personal advantage.
Corruption: Any form of corrupt practice, including embezzlement, nepotism, fraud,
or collusion.

4. Compliance with Laws
Bloomsbury Surveyors will:
Adhere to all laws relevant to countering bribery and corruption in all the jurisdictions
in which we operate, including the UK Bribery Act 2010.
Keep accurate and updated financial records and have appropriate internal controls
in place that will evidence the business reason for making payments to, and
receiving payments from, third parties.

5. Employee Responsibilities
All employees must:
Ensure that they read, understand, and comply with this policy.
Refrain from engaging in any form of bribery or corrupt practices.
Report any bribery or corruption offers or solicitations they encounter to their
supervisor or compliance officer.

6. Reporting Violations
Employees are encouraged to raise concerns about any instance of malpractice at
the earliest possible stage. Reports can be made anonymously and will be treated
confidentially. Retaliation against individuals who report wrongdoing in good faith will
not be tolerated.

7. Management Responsibilities
Senior Management must ensure that:
They set an example by their own conduct in accordance with this policy.
Bribery and corruption risks are assessed, monitored, and managed effectively.
Adequate resources and training are provided to employees to understand and
implement this policy.
They monitor compliance and deal with any violations appropriately.

8. Training and Communication
Training on this policy forms part of the induction process for all individuals who work
for us, and regular training will be provided as necessary. Our zero-tolerance
approach to bribery and corruption must be communicated to all suppliers,
contractors, business partners, and any third parties at the outset of our business
relationship with them and as appropriate thereafter.

9. Policy Review
This policy will be reviewed and updated regularly to ensure that it meets the
requirements of the law and reflects best practice. Changes to the policy will be
communicated in a timely manner to all staff.