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Anti-Bribery Policy

Version: 1.4
Dated: 1 February 2025

1. Purpose

SpotDev Services Ltd ("SpotDev") is committed to conducting business ethically, honestly and in full compliance with the Bribery Act 2010 and equivalent anti‑corruption laws in every country in which we operate. Bribery and corruption damage fair competition, expose the company to criminal liability and undermine trust with clients, employees and suppliers.

2. Scope

This policy applies to all employees, directors, contractors, temporary staff, consultants, interns and any third party acting on SpotDev’s behalf ("Associated Persons"). It also applies to our supply chain; suppliers must maintain equivalent standards and allow SpotDev to verify compliance.

3. Definitions

  • Bribe: An inducement or reward offered, promised, given or received to gain a commercial, contractual, regulatory or personal advantage.
  • Facilitation payment: A small, unofficial payment made to secure or speed up a routine action.
  • Foreign public official: Any person holding a legislative, administrative or judicial position of any country or territory outside the UK.

4. Policy Statement

  1. Zero tolerance. SpotDev prohibits bribery and corruption in all forms, whether direct or indirect.
  2. No facilitation payments. These are illegal under UK law; none may be made or accepted.
  3. Gifts & hospitality. Must be reasonable, proportionate and transparent. Anything valued over £100 requires written approval from the Chief Executive (incoming) or COO (outgoing) and must be recorded in the Gifts & Hospitality Register.
  4. Political and charitable donations. Only permitted with prior approval from the Chief Executive and must never be used to influence a business decision.
  5. Recruitment & secondments. Hiring decisions must be based on merit. Offering employment to secure advantage for SpotDev or a client is prohibited.
  6. Supply‑chain due diligence. Before onboarding a new supplier or subcontractor worth more than £10,000 per annum, the Operations team must complete a risk assessment.
  7. Record‑keeping. All business records, invoices and contracts must accurately reflect transactions. False or misleading entries are prohibited.
  8. Training. All employees must confirm that they have reviewed the ABC policy within 30 days of joining and thereafter every two years; higher‑risk roles receive annual refresher sessions.
  9. Reporting concerns. Suspicions of bribery must be reported immediately via hello@spotdev.co.uk. Retaliation is prohibited.
  10. Sanctions. Breaches will result in disciplinary action up to and including dismissal, termination of contracts and referral to law‑enforcement agencies.

5. Responsibilities

Role Responsibility
Board / Chief Executive Demonstrate top‑level commitment, approve the policy, review annual compliance reports.
Director of Operations (Policy Owner) Maintain the policy, oversee training and registers, coordinate investigations.
Line managers Embed the policy in day‑to‑day operations, ensure team completion of training.
All employees & Associated Persons Read, understand and comply; raise concerns promptly.

6. Risk Assessment & Adequate Procedures

SpotDev’s risk assessment (most recently updated January 2025) identified low inherent bribery risk (UK‑based clientele, professional‑services delivery). Controls implemented align with the six Ministry of Justice principles.

7. Monitoring & Review

The Director of Operations will:

  • Review this policy annually and after any significant incident or legal change.
  • Report compliance metrics (training completion rates, gifts register entries, incidents) to the Board each quarter.
  • Arrange an independent internal audit of ABC controls at least once every two years.

8. Acknowledgement

All employees must confirm their review of the policy via their ClickUp induction project.