1. Policy Statement

ZERO7 Group is committed to conducting business in a fair, transparent, and ethical manner. We operate a zero-tolerance approach to bribery and corruption and are committed to upholding the highest standards of integrity in all business dealings and relationships.

We fully comply with the UK Bribery Act 2010, and any breach of this policy may lead to disciplinary action, including dismissal, and could result in criminal prosecution.

 

2. Who This Policy Applies To

This policy applies to:

• All ZERO7 Group employees (full-time, part-time, temporary, and agency staff)
• Contractors, consultants, intermediaries, agents, sponsors, and any other third party acting on behalf of ZERO7 Group
• Subsidiaries and joint ventures under ZERO7 Group’s control

 

3. What Is Bribery?

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action that is dishonest, illegal, unethical, or in breach of trust.

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

1. Offering, promising or giving a bribe
2. Requesting, agreeing to receive, or accepting a bribe
3. Bribing a foreign public official
4. Failure of a commercial organisation to prevent bribery

Examples of bribery include:

• Paying a government official to speed up a permit process
• Accepting lavish gifts in return for awarding contracts
• Making “facilitation payments” to secure routine services

 

4. Prohibited Conduct

ZERO7 Group prohibits:

• Any form of bribery, whether direct or indirect
• The use of intermediaries to pay bribes on the company’s behalf
• Gifts, hospitality, or expenses that are intended to improperly influence business decisions
• Political contributions, unless specifically authorised
• Charitable donations made as a substitute for bribery

 

5. Gifts and Hospitality

ZERO7 Group allows reasonable, proportionate gifts and hospitality only if:

• They are given transparently, for legitimate business reasons
• They are not intended to influence a business decision
• They do not exceed £100 in value (unless pre-approved by management)
• They are recorded in the Gift and Hospitality Register

Lavish or frequent gifts/hospitality are strictly prohibited.

 

6. Facilitation Payments

ZERO7 Group strictly prohibits facilitation payments, which are unofficial payments made to speed up routine governmental actions. These are illegal under UK law, regardless of local custom.

 

7. Political and Charitable Donations

ZERO7 Group does not make political donations.
Charitable donations must be:

• Legal and ethical
• Approved by senior management
• Not used to gain a business advantage

 

8. Responsibilities

• Employees must read, understand, and comply with this policy
• Managers must ensure their teams are aware of and comply with the policy
• Third parties must agree to comply with our anti-bribery standards when acting on our behalf

The Compliance Officer (or designated lead) is responsible for:

• Monitoring effectiveness of the policy
• Handling bribery risk assessments
• Investigating reports of misconduct

 

9. Reporting Concerns (Whistleblowing)

ZERO7 Group encourages all staff and third parties to report any suspicions of bribery or corruption, without fear of retaliation. Reports can be made to:

• Line Manager
• Human Resources
• Compliance Officer

ZERO7 Group will investigate all reports thoroughly and confidentially.

 

10. Breach of Policy

Any breach may result in:

• Disciplinary action, including dismissal
• Termination of contracts with third parties
• Referral to the police or Serious Fraud Office (SFO)

 

11. Training and Communication

• Employees will receive training appropriate to their role and bribery risk
• This policy is communicated to all staff and relevant third parties
• Updates will be provided if the law or company practices change

 

12. Policy Review

This policy will be reviewed annually and updated as required to ensure continued compliance with UK legislation.

Rakesh Singh

CEO

ZERO7 Communications Limited