Anti-Bribery, Fraud and Corruption Policy
Version: V5.0. Date: May 2026. Review: Annually by Executive Board.
1. Introduction
The purpose of this policy is to set out the responsibilities of Agilexe and those who work for us in regard to observing and upholding our zero-tolerance position on bribery, fraud and corruption.
It also exists as a source of information and guidance for those working for Agilexe, helping them to recognise and deal with bribery, fraud and corruption issues, and to understand their responsibilities. If Agilexe is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation.
This anti-bribery, fraud and corruption policy is fully supported by the Board.
2. Policy Statement
Agilexe is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Agilexe has zero-tolerance for bribery, fraudulent and corrupt activities.
We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.
This policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.
3. Agilexe Responsibilities
With respect to anti-bribery, fraud and corruption measures, Agilexe will:
- Constantly uphold all laws relating to anti-bribery, fraud and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in our conduct both at home and abroad.
- Commit to preventing bribery, fraud and corruption in our business, and take our legal responsibilities seriously.
Adequate Procedures (Section 7 Bribery Act 2010)
Under Section 7 of the Bribery Act 2010, a commercial organisation commits an offence if a person associated with it bribes another person with the intention of obtaining or retaining business for that organisation, or an advantage in the conduct of business. It is a defence for the organisation to prove that it had adequate procedures in place to prevent such conduct.
Agilexe is committed to maintaining adequate procedures to prevent bribery. This policy, together with our associated training, reporting mechanisms, and management oversight, forms part of those adequate procedures. We review these procedures regularly to ensure they remain appropriate and effective.
Facilitation Payments
Facilitation payments are unofficial payments made to secure or speed up routine actions by government officials or others. These payments are illegal under the Bribery Act 2010 and are not permitted under any circumstances. Staff who are asked to make or facilitate such payments must refuse and report the matter immediately
4. Employee Responsibilities
All employees of Agilexe must ensure they:
- Read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery, fraud and corruption information provided to them.
- Understand the actions to be undertaken to prevent, detect, and report bribery, fraud and other forms of corruption.
- Avoid any activities that could lead to, or imply, a breach of this policy.
- Notify the compliance manager if they have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy.
If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Agilexe has the right to terminate a contractual relationship with an employee if they breach this policy.
5. Gifts and Hospitability
Staff must not offer or accept gifts, hospitality, or other benefits that could reasonably be perceived as influencing a business decision or creating an obligation. The following principles apply to all staff:
- Gifts or hospitality of nominal value (for example, a pen or a branded item of modest worth) may be accepted in the ordinary course of business.
- Any gift or hospitality of material value received by a member of staff in connection with their role at Agilexe must be declared to management promptly. Agilexe maintains a gifts and hospitality register for this purpose.
- Staff must never offer gifts, hospitality or other benefits to government officials, procurement officers, or other third parties in a way that could constitute bribery or give that impression.
- Seasonal gifts to clients or suppliers should be modest, appropriate, and consistent with normal business practice.
If you are uncertain whether accepting or offering something is appropriate, speak to your line manager or the compliance manager before proceeding.
6. Reporting
If you suspect that there is an instance of bribery, fraud or corrupt activities occurring in relation to Agilexe, you are encouraged to raise your concerns at as early a stage as possible. If you are uncertain about whether a certain action or behaviour can be considered bribery, fraud or corruption, you should speak to your line manager, the compliance manager, or the director(s).
Agilexe will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially. Details of the whistleblowing procedure are available from your line manager or the compliance manager. You must tell the compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.
Concerns may also be raised by contacting us at: Email: info@agilexe.co.uk
7. Confidentiality
If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Agilexe understands that you may feel worried about potential repercussions. Agilexe will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.
Agilexe will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities, or because they reported a concern relating to potential act(s) of bribery or corruption.
8. Review
This anti-bribery, fraud and corruption policy is to be reviewed annually by the Executive Board, who will ensure that any changes are clearly communicated to all staff and other stakeholders.
Where appropriate, third parties may be sought to assist in the review process and to assist with the communication of changes to stakeholders outside Agilexe.
9. Definitions
The following definitions apply throughout this policy.
Fraud is knowingly making an untrue or misleading representation with the intention of making a gain for oneself or another, or causing a loss or risk of loss to another.
Bribery is giving or offering someone a financial or other advantage to encourage that person to perform their functions or activities improperly, or to reward someone for having already done so.
Corruption is the misuse of entrusted power for personal gain. This includes dishonest or fraudulent behaviour by those in positions of power, such as managers or government officials. It includes offering, giving and receiving bribes to influence the actions of someone in a position of power or influence, and the diversion of funds for private gain.
A conflict of interest is where an individual has private interests that may or do influence the decisions they make as an employee or representative of an organisation.
Agilexe | Anti-Bribery, Fraud and Corruption Policy V5.0 | May 2026