# ANTI-BRIBERY AND CORRUPTION POLICY
Date: 1 August 2029
Parties: Brightwell Engineering plc and its group personnel and business associates
## 1. Parties and purpose
Brightwell Engineering plc (Company No. 04188221) adopts this policy for directors, employees, workers, contractors and group companies under its control. It applies to dealings in the UK and overseas and supports the Bribery Act 2010. No commercial target, customer request or local custom justifies an improper payment or advantage.
## 2. Scope, price and subject
Bribery includes offering, promising, giving, requesting or accepting a financial or other advantage intending to induce improper performance, and a bribe to a foreign public official. Facilitation payments are prohibited, even if customary. A payment demanded under an immediate threat to life or safety must be recorded and reported as soon as safe.
## 3. Operating duties
Gifts and hospitality must be modest, transparent, infrequent, connected to a legitimate business purpose and never offered during a live tender to influence a decision. Anything over £100 per person, travel for a public official, charitable donation linked to a decision, or sponsorship requires Compliance approval and the register entry.
## 4. Compliance, records and controls
Third parties, agents and distributors receive written contractual controls, proportionate due diligence, training and audit rights. Compliance escalates red flags including secrecy, success fees, unusual bank accounts, public-official connections and refusal to certify. Procurement must not split invoices or use an intermediary to evade this policy.
## 5. Term, ending and remedies
Employees must keep accurate books and records, use approved payment channels and never create a false invoice or off-book fund. Suspected conduct is reported to the Compliance Officer through the confidential hotline or directly to the Chair of the Audit Committee. Retaliation against a good-faith report is prohibited and protected disclosures remain available.
## 6. Liability and reservations
Breaches may lead to investigation, suspension, disciplinary action up to dismissal, contract termination, recovery of money and referral to law enforcement. Annual training is mandatory for higher-risk roles; the Compliance Officer tests controls, reports quarterly to the Board and reviews this policy each August or after a material incident.
## 7. Governing law and signatures
Brightwell’s Board approves the policy on 1 August 2029. English law governs the policy’s contractual application where incorporated into an agreement, but it does not remove statutory duties or whistleblowing rights. The Group General Counsel and Chair sign, and each business unit must acknowledge local implementation.