Policies Coherence Strategy Ltd
Inner-Coherence
Anti-Bribery and Anti-Corruption Policy
Purpose
This policy establishes the controls needed to ensure compliance with anti-bribery and anti-corruption laws, including the Bribery Act 2010 in the UK and relevant international legislation. It reflects Coherence Strategy Ltd.’s commitment to ethical and transparent business practices.
Policy Statement
Bribery and corruption involve offering, giving, receiving, or soliciting an advantage as an inducement for action. Coherence Strategy Ltd. enforces a zero-tolerance approach to any form of bribery or corruption. We are committed to acting with integrity and fairness in all business dealings.
Failure to comply can result in severe penalties, including imprisonment and unlimited fines for individuals and the company, along with reputational damage. We are determined to uphold the highest ethical standards and legal responsibilities.
Scope
This policy applies to all employees, contractors, consultants, suppliers, and third parties engaged with Coherence Strategy Ltd., both in the UK and internationally.
Key Areas Covered
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Bribes: No employee or third party acting on behalf of the company may engage in bribery.
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Gifts and Hospitality: Must not exceed £100 per gift or £500 per event, with an annual limit of £1,000, unless approved by management. Any gift or hospitality that could influence or appear to influence business decisions is strictly prohibited.
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Facilitation Payments and Kickbacks: Facilitation payments are prohibited, except in extreme situations where personal safety is at risk. Any such payments must be recorded and reported to management.
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Political Contributions: Coherence Strategy Ltd. does not make any donations to political parties or candidates.
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Charitable Contributions: Donations must be legal, ethical, and transparent, with prior approval from the compliance manager.
Employee Responsibilities
Employees must comply with this policy and report any suspicions of bribery or corruption to their line manager or a Company Director. Breaching this policy can result in disciplinary action, including dismissal.
Record-Keeping
All business transactions, including expenses, gifts, and hospitality, must be accurately recorded. Financial records will be audited regularly to ensure compliance.
Reporting Concerns
Employees are encouraged to raise any concerns about possible bribery or corruption. Reports can be made confidentially, and employees will be protected from retaliation for reporting in good faith.
Training and Communication
All employees will receive training on this policy during onboarding and through regular updates. Our anti-bribery stance must be communicated to suppliers and business partners.
Monitoring and Review
The Company Secretary is responsible for overseeing compliance with this policy and will review its effectiveness annually, ensuring ongoing suitability and adequacy.
Date: 16 March 2025
Approved by: Morna Simpson
