# ANTI-CORRUPTION AND BRIBERY POLICY
Date: 3 February 2031
Parties: Quayside Renewables Limited and its personnel and business partners
## 1. Purpose and parties
Quayside Renewables Limited adopts this policy for directors, employees, agency workers and contractors in England and Wales and for third parties acting on its behalf. It is designed as proportionate anti-bribery procedures, not a guarantee that misconduct cannot occur.
## 2. Facts, scope and terms
No person may offer, promise, give, request or accept a financial or other advantage intending to induce improper performance. Particular care applies to public officials, procurement decisions, charitable donations, sponsorship, gifts and hospitality. Hospitality must be reasonable, transparent and approved at the stated thresholds.
## 3. Process and responsibilities
Facilitation payments are prohibited, even if locally described as routine, except where a person faces an immediate threat to life or safety; the payment and circumstances must be reported promptly. A payment demanded under duress is not silently reimbursed and must be escalated to Compliance.
## 4. Evidence, records and safeguards
Before appointment, Compliance assesses agents, distributors and consultants for ownership, reputation, services, remuneration and public-official connections. Contracts require compliance undertakings, audit access, accurate invoices and termination for breach. Training is risk-based and completion is recorded.
## 5. Review, escalation and outcome
A concern may be reported to speakup@quayside.example, a line manager or the independent hotline. Retaliation is prohibited; reports are investigated confidentially and fairly, with records, conflicts checks and referrals to law enforcement where appropriate. The company will not destroy evidence or coach witnesses.
## 6. Reservations and practical protections
The board reviews risk annually and after a material incident. Employees must declare conflicts and keep gifts and hospitality registers; a breach may lead to discipline, contract termination or reporting. The policy does not prevent lawful payments, legitimate expenses or whistleblowing protections.
## 7. England and Wales law and completion
The policy is approved on 3 February 2031 under England and Wales law and the Bribery Act 2010, including the corporate failure-to-prevent offence. It is reviewed every 12 months; Marcus Lee, Chair, approves it.