Anti-Fraud, Bribery and Corruption Policy

1. Document Control

2. Purpose

EnableAll Limited is committed to conducting its business with honesty, integrity, and transparency, and to preventing fraud, bribery, and corruption in all its activities.

This policy sets out the organisation’s zero-tolerance approach to fraud, bribery, and corruption, and provides guidance on recognising, preventing, and reporting such activity in line with UK law and best practice.

3. Scope

This policy applies to all employees, directors, agency workers, contractors, consultants, volunteers, and any third parties acting on behalf of EnableAll Limited.

It covers all business activities and transactions undertaken in the UK or overseas

4. Policy Statement

EnableAll Limited will not tolerate fraud, bribery, or corruption in any form.

All individuals covered by this policy are expected to act ethically and lawfully at all times and to avoid any activity that could lead to, or suggest, a breach of this policy.

Any breach of this policy may result in disciplinary action, up to and including dismissal, and may also result in civil or criminal proceedings.

5. Roles and Responsibilities

6. Legislative Framework

This policy is informed by, and complies with, the following UK legislation:

• Bribery Act 2010
• Fraud Act 2006
• Proceeds of Crime Act 2002
• Public Interest Disclosure Act 1998
• UK GDPR and Data Protection Act 2018

7. Definitions

Fraud: A dishonest act or omission intended to make a gain or cause a loss, including false representation, failure to disclose information, or abuse of position.

Bribery: The offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action that is illegal, unethical, or a breach of trust.

Corruption: The misuse of entrusted power for private gain, including offering or accepting inducements or favours that improperly influence decision making.

Gifts and Hospitality: Any item of value, benefit, or service offered or received at less than commercial value, excluding modest hospitality of a reasonable and proportionate nature.

Facilitation Payments: Payments made to secure or speed up routine governmental actions. These are prohibited.

8. Fraud Prevention

All individuals must:

• Act honestly and with integrity
• Safeguard company assets
• Maintain accurate records
• Never use off-book accounts

Suspected fraud must be reported immediately.

9. Bribery and Corruption

Bribes: Bribery is strictly prohibited. No individual may offer, give, request, or accept a bribe, whether directly or indirectly, through third parties.

Gifts and Hospitality:

• Must never be offered or accepted to influence business decisions
• Must be reasonable, proportionate, and infrequent
• Cash or cash equivalent gifts are prohibited
• All gifts and hospitality must be approved in advance by a Director and recorded in the Gifts and Hospitality Register

Political Contributions:EnableAll Limited does not make political donations or contributions, whether in cash or in kind.

Charitable Donations:

• Be made in good faith and for legitimate purposes
• Be approved in advance by two Directors
• Be properly recorded and publicly transparent

Facilitation Payments: Facilitation payments are strictly prohibited under the Bribery Act 2010. Any request for such a payment must be refused and reported immediately.

Sponsorship

• Be for a legitimate business purpose
• Be proportionate and transparent
• Be approved by a Director and recorded appropriately

10. Raising Concerns and Whistleblowing

EnableAll Limited encourages the reporting of any reasonable suspicions of fraud, bribery, or corruption.

Concerns may be raised:

• With a line manager
• With the Head of Finance
• Via the Whistleblowing Policy

Individuals who raise concerns in good faith will be protected from victimisation in accordance with the Public Interest Disclosure Act 1998.

11. Investigations and Enforcement

All reported concerns will be investigated promptly, fairly, and confidentially.

Where wrongdoing is identified:

• Disciplinary action may be taken
• Matters may be referred to external authorities
• Contractual relationships may be terminated

12. Related Policies

• Whistleblowing Policy
• Financial Controls Policy
• Disciplinary Policy
• Gifts and Hospitality Procedure

13. Review and Maintenance

This policy will be reviewed annually or sooner if required due to changes in legislation, risk profile, or business operations.

14. Revision History