Anti-Bribery and Corruption Policy

This policy explains how Lead Conneqt Limited prevents bribery and corruption in its own business and in the outsourced sales development work we carry out for clients. Our position is straightforward: we have zero tolerance for bribery and corruption in all forms, whether committed by us, on our behalf, or towards us.

The policy is written to support compliance with applicable United Kingdom anti-bribery legislation, including the Bribery Act 2010, which makes it an offence to offer, promise or give a bribe, to request, agree to receive or accept a bribe, and to bribe a foreign public official. A commercial organisation can also commit an offence where a person associated with it bribes another person intending to obtain or retain business or an advantage for it.

For the purposes of this policy, a bribe means offering, giving, requesting or accepting any financial or other advantage in order to induce or reward the improper performance of a function or activity, or to influence a decision improperly. It does not matter whether the advantage is given directly or through somebody else, whether it is money or something else of value, or whether the attempt succeeds.

This policy applies to everyone who acts for or on behalf of Lead Conneqt Limited, wherever they are located, and applies to every part of our activity, including outreach and appointment setting performed on behalf of clients.

• Directors and officers of the company
• Anyone employed or engaged by the company, including contractors, freelancers and temporary workers
• Agents, intermediaries and any other third party performing services for us or in our name
• Suppliers and partners, to the extent set out in this policy and in the terms on which we engage them
• All dealings with clients, prospects, suppliers, public bodies and public officials, in the United Kingdom and in any other country in which we operate or to which our outreach is directed

We conduct business on the merits of the service we provide. We do not seek advantage through improper payments or favours, and we do not accept business won that way.

• We do not offer, promise or give a bribe to any person, in any form, directly or through a third party
• We do not request, agree to receive or accept a bribe from any person, in any form, directly or through a third party
• We do not make facilitation payments of any kind, meaning small unofficial payments made to secure or speed up a routine action to which we are already entitled, and we will not authorise anyone to make one on our behalf
• We do not offer anything of value to a public official, or to a person connected with a public official, in order to obtain or retain business or any other advantage
• We do not use commission, referral fees, sponsorship, charitable donations, work experience, employment offers or discounts as a disguised means of improperly influencing a decision
• We do not make political donations on behalf of the company in order to gain a business advantage
• We will not penalise anyone for refusing to pay or accept a bribe, or for turning away business as a result, even where doing so costs us the work
• We will co-operate with law enforcement and regulators in relation to any credible allegation of bribery or corruption involving our business

Modest business courtesies are a normal part of commercial life and are not prohibited by this policy. What matters is intent and appearance. A gift or hospitality item must never be given or received in order to influence a decision improperly, to reward improper performance, or to place the recipient under any obligation.

• Gifts and hospitality must be reasonable and proportionate to the relationship and the occasion, and must be given openly rather than in secret
• They must be given or received in the company’s name where appropriate, and never in cash or as a cash equivalent such as a voucher redeemable for cash
• They must not be offered or accepted during a live tender, bid, negotiation or procurement decision where they could reasonably be seen to influence the outcome
• They must comply with the rules of the recipient’s own organisation, which in some cases will prohibit gifts and hospitality entirely
• Nothing of value may be offered to a public official in order to obtain or retain business or any other advantage
• Facilitation payments are prohibited without exception, however small and however routine the action being sought

If a person acting for us is asked for a facilitation payment, or is offered anything that appears intended to influence their judgement, they must decline, remove themselves from the situation where it is safe to do so, and report it using the route set out below. Where personal safety is genuinely at risk, the immediate priority is safety, and the incident must be reported at the earliest opportunity afterwards.

We can be held responsible for the conduct of people who act on our behalf, so we hold third parties to the standards in this policy.

• We require suppliers, partners, agents, subcontractors and any other third party acting for us to comply with this policy, or with their own standards where those are at least equivalent
• We take reasonable and proportionate steps to satisfy ourselves that we understand who we are engaging and what they will be paid for before we appoint them, and we pay only for services actually provided
• We reserve the right to suspend or end any relationship, and to terminate the relevant contract in accordance with its terms, where there is a serious breach of this policy or credible evidence of bribery or corruption
• Anyone acting for us must declare any personal, financial or family interest that conflicts, or could reasonably be seen to conflict, with their duties to the company, including any interest in a supplier, client or prospect
• Declared conflicts must be managed openly, which will normally mean removing the person from the decision in question
• Anyone acting for us must keep accurate and complete records of gifts and hospitality offered, given, requested or received, of expenses claimed, and of payments made to third parties, so that the reason for a decision can be explained and evidenced later
• Records must not be falsified, backdated or left deliberately vague, and no off-book account or arrangement may be used for any purpose covered by this policy

Responsibility for this policy is held at the top of the business, and every person acting for the company has a personal duty under it.

• The Managing Director owns this policy, is accountable for its content, and makes the final decision on any question of interpretation or on any relationship that must be ended under it
• Everyone acting for the company must read this policy, follow it, and avoid any activity that might lead to a breach of it
• Anyone who engages a supplier, agent or subcontractor on our behalf is responsible for making our expectations clear to that party before work begins
• Anyone who becomes aware of a possible breach, or is asked to do something that would breach this policy, must report it promptly and must not deal with it privately
• No manager or colleague has authority to instruct another person to breach this policy, and any such instruction must be refused and reported

If you suspect bribery or corruption connected with our business, or you are offered or asked for a bribe, report it to dane@leadconneqt.com. This route is open to our own people and to clients, suppliers, prospects and members of the public. Please include what happened, who was involved and when, so far as you know it, and say if you have any supporting material.

Concerns raised under this policy are taken seriously and are handled confidentially so far as is reasonably possible. There are limits to confidentiality, for example where we are required to disclose information to law enforcement or a regulator, and we will be honest with you about that if it arises.

Nobody who raises a concern in good faith will suffer detriment or retaliation as a result, including where the concern later turns out to be mistaken. That protection covers dismissal, loss of work, exclusion from opportunities and any other unfavourable treatment. Retaliation against a person who has raised a concern is itself a breach of this policy and will be treated as such. Nothing in this policy prevents anyone from reporting suspected criminal conduct directly to the police or to another competent authority.

Bribery is a criminal offence for the individuals involved and can be an offence for the company. On conviction on indictment under the Bribery Act 2010, an individual can face imprisonment, an unlimited fine, or both, and an organisation can face an unlimited fine.

• Breaches by anyone employed or engaged by us are dealt with through the appropriate disciplinary or contractual route, up to and including dismissal or termination of the engagement
• Breach by a supplier or partner may result in suspension of the relationship and termination of the contract in accordance with its terms
• Where we identify conduct that may be criminal, we will consider our legal obligations and report it to the appropriate authorities where it is right to do so
• We will act on breaches consistently regardless of the seniority of the person involved or the value of the business at stake

This policy is reviewed at least annually, or sooner if there is a material change to the business, its services, its supply chain or the law. The owner of this policy is the Managing Director, who approves each version before it is published.