Anti-Bribery & Anti-Corruption Policy

Purpose of This Policy

This policy defines the responsibilities of everyone working for or on behalf of Elandel Global Services Limited in upholding our strict zero-tolerance stance on bribery and corruption. It also serves as guidance to help employees and partners recognize, prevent, and properly address bribery and corruption risks.

Policy Statement

Elandel Global Services is committed to conducting business ethically, transparently, and with integrity. We have zero tolerance for bribery or any form of corrupt practice.

We comply fully with the UK Bribery Act 2010 and all other applicable anti-bribery and anti-corruption laws in the jurisdictions where we operate.

We recognize that engaging in bribery or corruption can result in severe criminal penalties, including imprisonment, heavy fines, disqualification from contracts, and irreparable reputational damage. Accordingly, we take our legal and ethical responsibilities seriously and are dedicated to preventing bribery in every aspect of our business.

Scope of Application

This policy applies to:

  • All employees of Elandel Global Services, regardless of contract type (permanent, temporary, fixed-term, agency, casual, or trainee).

  • Officers, trustees, board and committee members.

  • Consultants, contractors, agents, intermediaries, sponsors, distributors, and volunteers.

  • Third parties acting on behalf of Elandel or engaged in any business relationship with us.

“Third party” includes clients, customers, suppliers, business contacts, advisers, government officials, political representatives, and their affiliates.

All contractual arrangements with third parties must contain provisions requiring compliance with this policy.

Definition of Bribery

  • Bribery is the act of offering, promising, giving, requesting, or accepting anything of value to improperly influence a decision or secure an undue advantage.

  • A bribe may be cash, gifts, hospitality, services, favors, or any benefit that creates an improper obligation.

  • Both giving and receiving bribes are illegal.

No employee or associated party may offer or accept bribes, directly or indirectly, or attempt to influence foreign or domestic officials improperly.

What Is Acceptable and What Is Not

This policy specifically addresses:

  1. Gifts and Hospitality

    • Modest, reasonable, and transparent gestures of goodwill are acceptable when:

      • They are not intended to influence business decisions or gain improper advantage.

      • They comply with local laws and cultural practices.

      • They are openly given in the company’s name (not an individual’s).

      • They exclude cash or cash equivalents.

      • Their value is reasonable (typically under £100) and pre-approved if above this threshold.

      • They are declared to the compliance manager.

    • Gifts or hospitality must not be offered to government officials, politicians, or political representatives without prior approval.

  2. Facilitation Payments and Kickbacks

    • Elandel strictly prohibits facilitation payments (small payments to expedite routine actions) and kickbacks.

    • If refusal creates a genuine risk to personal safety, the employee must:

      • Keep the payment minimal.

      • Obtain a receipt.

      • Record the details.

      • Report immediately to their line manager.

  3. Political Contributions

    • Elandel does not make political donations in cash, kind, or services. Such contributions could be perceived as attempts to gain improper influence.

  4. Charitable Contributions

    • We encourage lawful, transparent charitable giving.

    • All donations require compliance manager approval and must not be used to disguise bribery.

Employee Responsibilities

  • Read, understand, and comply with this policy and related training.

  • Avoid any activity that could be seen as bribery or corruption.

  • Promptly report suspected or actual bribery to the compliance manager.

  • Understand that breaches of this policy may result in disciplinary action, including dismissal, and possible legal consequences.

Raising Concerns & Whistleblowing

Employees are encouraged to report concerns at the earliest opportunity. Reports may be made to a line manager, compliance manager, or senior leadership.

  • If you are offered a bribe: report immediately.

  • If you suspect bribery: raise the issue without delay.

  • If you refuse a bribe: you will be fully supported and protected.

Elandel prohibits retaliation against anyone who reports concerns in good faith. Unfavorable treatment such as dismissal, demotion, threats, or discrimination will not be tolerated.

Training & Communication

  • Anti-bribery training will be provided to all new employees and refreshed regularly.

  • Contractors, suppliers, and business partners will be made aware of Elandel’s zero-tolerance approach.

  • Additional targeted training will be given to staff in higher-risk roles.

Record Keeping

  • All financial transactions must be accurately recorded.

  • Records of gifts, hospitality, and donations must be kept, reviewed, and monitored.

  • Transparency in all dealings is mandatory.

Monitoring & Review

The compliance manager is responsible for overseeing the implementation of this policy, supported by regular audits and reviews.

Feedback from employees is welcomed to ensure continuous improvement. This policy may be updated at any time to strengthen its effectiveness.

Conclusion
Elandel Global Services is fully committed to upholding the highest standards of integrity, fairness, and accountability. Bribery and corruption undermine trust, and we are determined to prevent them in all areas of our business operations.