Anti-bribery & Corruption Policy

1. Policy statement

Sifotech UK Ltd commits to conducting business with integrity and to fully complying with the UK Bribery Act 2010 and equivalent anti-corruption laws wherever we operate. We will not offer, give, request or accept bribes — directly or indirectly — under any circumstances. We expect the same standard of our staff, contractors, suppliers and customers.

2. Definitions

• Bribery means offering, promising, giving, requesting or accepting a financial or other advantage to induce or reward improper performance of a function or activity.
• Corruption means the abuse of entrusted power for private gain.
• Foreign public official has the meaning given in section 6 of the Bribery Act 2010.
• Facilitation payment means a small, typically unofficial, payment made to secure or expedite a routine action.
• Associated person means any person who performs services for or on behalf of Sifotech (including contractors, agents and suppliers).

3. Scope

This policy applies to everyone working for or on behalf of Sifotech, anywhere in the world, and to all interactions with customers (including UK public-sector buyers), suppliers, partners, government officials and intermediaries.

4. Gifts and hospitality

Reasonable and proportionate gifts and hospitality are part of normal business. Anything that could reasonably be perceived as influencing a decision is not. Specifically:

• Gifts to or from a third party with a market value above £50 (single occurrence) or £150 (cumulative per third party per year) require written approval from the director.
• No gift or hospitality of any value may be offered to, or accepted from, a UK public-sector official, a foreign public official, or anyone involved in a live tender or procurement evaluation. Routine refreshments at meetings are exempt.
• Cash and cash-equivalents (gift cards, cryptocurrency) are never permitted, regardless of value.
• All approved gifts and hospitality given or received are recorded in the gifts register.

5. Facilitation payments

Facilitation payments are prohibited in any jurisdiction, in any amount, irrespective of local custom. If a facilitation payment is demanded under threat of personal safety, staff should comply if necessary to remove the threat and report the demand immediately to the director.

6. Charitable contributions

Charitable donations are made only to registered UK charities, in line with our values, and never as a substitute for a prohibited gift or to influence a business decision. Donations of more than £500 require written approval from the director.

7. Political contributions

Sifotech does not make political donations. Staff may participate in political activity in a personal capacity but must not use Sifotech resources, time or branding to do so.

8. Records and approvals

We keep a written gifts and hospitality register covering all approved transactions above the de-minimis thresholds in section 4. Records are retained for at least seven (7) years to support tax, audit and procurement disclosures.

9. Reporting and investigations

Anyone with a concern, suspicion or knowledge of a possible breach of this policy must report it without delay to hello@sifotech.co.uk. Reports made in good faith will not result in retaliation. Reports will be investigated promptly and, where appropriate, referred to law enforcement and to relevant procurement authorities. Staff may also report concerns directly to the Serious Fraud Office or the National Crime Agency.

10. Sanctions for breach

Breach of this policy by a member of staff or contractor is a disciplinary offence and may result in summary termination of engagement. Breach by a supplier or partner may result in immediate termination of the relevant contract. Individuals may also face personal criminal liability under the Bribery Act 2010, with penalties including unlimited fines and imprisonment of up to ten (10) years.