Anti-Bribery Policy

Version: 1.6
Effective date: 6 Sep 2026
Next review: 6 Sep 2027
Owner: COO
Approver: Chief Executive

1. Purpose and scope

SpotDev Services Ltd prohibits bribery and corruption and requires honest, ethical business conduct. This policy applies to directors, employees, contractors, temporary staff, consultants and other persons acting on our behalf, wherever they work. Suppliers and intermediaries are expected to uphold equivalent standards relevant to their relationship with us.

2. Prohibited conduct

No person acting for SpotDev may offer, promise, give, request or accept an improper advantage to influence a decision, secure business or reward improper conduct. This includes indirect arrangements through another person. Facilitation payments are prohibited.

Recruitment, secondments, discounts, gifts and donations must not be used to obtain an improper advantage. Business records must accurately describe transactions; false invoices, concealed payments and misleading records are prohibited.

3. Gifts, hospitality and donations

Gifts and hospitality must be reasonable, proportionate, transparent and consistent with a legitimate business relationship. Anything valued above £100 requires prior written approval from the Chief Executive for incoming benefits or the COO for outgoing benefits, and must be recorded in the Gifts and Hospitality Register. Items below the threshold are still prohibited if improper. Repeated benefits must not be used to avoid approval.

Political or charitable donations require prior Chief Executive approval and must never be used improperly to influence a business decision.

4. Risk and supplier assessment

Our assessments must consider the countries, sectors, transactions, intermediaries and relationships involved, including contact with public officials and persons acting on our behalf. Professional-services delivery does not eliminate bribery risk.

Before onboarding a supplier or subcontractor worth more than £10,000 annually, the Operations function must complete a risk assessment. Lower-spend relationships also require assessment where risk warrants it. This threshold does not exempt any supplier from applicable security, data-protection or third-party-risk requirements.

Records of assessment, approval and relevant contractual safeguards must be retained under controlled record-keeping arrangements.

5. Responsibilities and awareness

The Chief Executive approves this policy and oversees material compliance concerns. The COO maintains the policy, coordinates assessments, training and registers, and oversees investigation arrangements. Managers ensure relevant requirements are understood and followed.

Employees must acknowledge this policy within 30 days of joining and every two years thereafter. Higher-risk roles require annual refresher training. Acknowledgement is recorded through the approved onboarding or training process.

6. Reporting and response

Report suspected bribery promptly to hello@spotdev.co.uk, requesting the attention of the COO or Chief Executive. If a concern involves one of those roles, ask for it to be directed to the other. Information is handled sensitively and shared only where needed to assess or address the concern.

Retaliation for reporting a genuine concern is prohibited. Suspected breaches are assessed and may result in disciplinary action, termination of a business relationship or referral to the relevant authority, as appropriate.

7. Monitoring and review

The COO is responsible for annual review and review following material changes or incidents. Quarterly compliance reporting should address acknowledgement/training, gifts and hospitality, concerns and remedial actions. Independent internal audit of anti-bribery controls is required at least every two years. Reviews and resulting actions must be recorded.