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Anti-Bribery, Whistleblowing & Corruption Policy

FooEngine Limited is committed to the highest standards of ethical conduct, integrity and transparency in all business activities. Every person working for or representing FooEngine is responsible for conducting Company business honestly and professionally.

This policy sets out:

  • Our approach to whistleblowing
  • Our zero-tolerance position on bribery and corruption
  • How to raise concerns safely

Whistleblowing

What is Whistleblowing?

Whistleblowing is reporting suspected wrongdoing that affects others or the wider public interest. UK law protects whistleblowers under the Employment Rights Act 1996.

FooEngine encourages anyone working for or with the Company to raise genuine concerns without fear of retaliation.

Qualifying Disclosures

A protected disclosure is information that you reasonably believe shows one or more of the following:

  • Criminal offences (e.g. fraud, theft, bribery)
  • Breach of legal obligations
  • Miscarriage of justice
  • Endangerment of health or safety
  • Environmental damage
  • Deliberate concealment of any of the above
  • Serious information security or data protection failures

Examples include:

  • Data breaches or loss of devices containing personal data
  • Unauthorised system access
  • Deliberate misuse of confidential information
  • Financial irregularities
  • Unsafe working practices

How to Raise a Concern

Concerns should be reported as soon as possible to:

  • CEO or CTO
  • Senior Management

Concerns may be raised verbally or in writing.

Anonymous disclosures will be accepted, although this may limit investigation.

All concerns will be treated seriously, sensitively and confidentially.

Protection for Whistleblowers

No employee or contractor will suffer:

  • Dismissal
  • Disciplinary action
  • Loss of work
  • Harassment
  • Any other detrimental treatment

for making a genuine protected disclosure.

Any retaliation against a whistleblower will itself be treated as a serious disciplinary matter.

Anti-Bribery & Corruption

FooEngine operates a zero-tolerance approach to bribery and corruption. We conduct business fairly, honestly and transparently.

A bribe is any financial or other advantage offered, given, requested or received to influence someone improperly in their duties.

Prohibited Conduct

No employee, contractor or representative of FooEngine may:

  • Offer or give a bribe
  • Request or accept a bribe
  • Make facilitation payments
  • Authorise others to engage in bribery

Gifts & Hospitality

Reasonable and proportionate hospitality and gifts may be offered or accepted where they are:

  • Of modest value
  • Given openly and transparently
  • Not intended to influence decisions

Guidelines:

  • Gifts should not normally exceed £50 in value
  • No cash or cash-equivalent gifts
  • Gifts should be infrequent
  • Gifts should be for business, not personal benefit
  • Gifts above £50 require approval from a Director
  • A simple record of gifts over £50 must be kept

Third Parties

FooEngine will not engage with suppliers, agents or partners who do not support our anti-bribery principles. Third-party conduct may be reviewed where necessary.

Reporting Bribery Concerns

Any concerns relating to bribery or corruption should be reported to:

  • CEO or CTO
  • Or raised through the Whistleblowing process above

Breaches

Breach of this policy may result in:

  • Disciplinary action
  • Summary dismissal for gross misconduct
  • Termination of contractor agreements

Bribery is a criminal offence under the Bribery Act 2010 and may result in fines and/or imprisonment.

No Retaliation

No one raising a genuine concern under this policy will suffer any detriment for doing so.