1: Introduction

1.1 Policy Overview
United Civils Limited is committed to maintaining the highest standards of honesty, integrity, and ethical conduct. This Policy sets out our zero-tolerance approach to bribery and corruption and provides guidance to ensure compliance with the Bribery Act 2010.

1.2 Statement of Commitment
United Civils Limited prohibits all forms of bribery and corrupt activity by its employees, subcontractors, suppliers, and third parties acting on its behalf. We expect all business to be conducted fairly, transparently, and in accordance with the law.

2: Purpose

2.1 Objectives of the Policy
The objectives of this Policy are to:

2.1.1 Prevent bribery and corrupt practices in all United Civils Limited operations.
2.1.2 Provide clear rules and responsibilities for all employees and representatives.
2.1.3 Ensure compliance with the Bribery Act 2010 and protect the reputation of the company.
2.1.4 Encourage reporting of concerns without fear of retaliation.

3: Scope

3.1 Applicability
This Policy applies to:

• All employees, including directors, managers, and operatives.

• Subcontractors and consultants working on behalf of United Civils Limited.

• Suppliers, agents, and other third parties acting for or connected to the company.

3.2 Activities Covered
The Policy applies to all business dealings, including:

• Bidding for contracts

• Procurement and supplier engagement

• Payments and invoicing

• Gifts, hospitality, and sponsorships

• Client and public sector interactions

4: Definitions and Prohibited Conduct

4.1 Bribery Defined
Bribery is offering, promising, giving, requesting, or accepting a financial or other advantage to induce or reward improper performance of a role or activity.

4.2 Common Forms of Bribery

4.2.1 Offering cash or gifts to secure contracts or favourable treatment.
4.2.2 Accepting hospitality in exchange for preferential decisions.
4.2.3 Facilitating payments to speed up services from public officials.
4.2.4 Providing subcontractor roles in return for personal benefit.

4.3 Prohibited Activities

4.3.1 Offering or accepting bribes under any circumstances.
4.3.2 Authorising, assisting, or ignoring corrupt behaviour.
4.3.3 Using third parties to carry out bribery on behalf of the company.
4.3.4 Failing to report known or suspected bribery.

5: Roles and Responsibilities

5.1 Managing Director – Scott Bland

5.1.1 Holds overall accountability for anti-bribery compliance and ethical leadership.
5.1.2 Ensures resources and controls are in place to prevent corruption.

5.2 HSEQ Consultants – SEHSS Limited

5.2.1 Provides guidance on compliance, risk identification, and training.
5.2.2 Investigates concerns and supports disciplinary proceedings where required.

5.3 All Employees and Subcontractors

5.3.1 Must not engage in bribery, directly or indirectly.
5.3.2 Must report any suspicion or evidence of bribery to Kevin Sanders or Scott Bland immediately.
5.3.3 Are required to act in a manner that upholds the reputation and legal compliance of United Civils Limited.

6: Gifts and Hospitality

6.1 Acceptable Practice

6.1.1 Modest hospitality or gifts of low value (e.g., branded pens, modest meals) may be acceptable if:

• They are not intended to influence decisions or gain advantage.

• They are declared to management in advance or retrospectively.

6.2 Unacceptable Practice

6.2.1 Cash gifts, lavish entertainment, or unrecorded benefits are not permitted.
6.2.2 Anything that could be seen as influencing a decision must be refused.

7: Due Diligence and Third Parties

7.1 United Civils Limited will conduct proportionate checks on suppliers, subcontractors, and partners to assess integrity and reduce bribery risk.

7.2 Contracts will include clauses requiring third parties to comply with anti-bribery laws and this Policy.

8: Reporting and Whistleblowing

8.1 Reporting Process

8.1.1 Employees or third parties are encouraged to raise concerns confidentially with Scott Bland.
8.1.2 All reports will be investigated promptly, fairly, and without victimisation of the whistleblower.

8.2 Protection for Whistleblowers

8.2.1 Anyone reporting concerns in good faith will be protected from retaliation.
8.2.2 Confidentiality will be maintained wherever possible.

9: Breaches and Disciplinary Action

9.1 Any breach of this Policy will be treated as a serious offence and may lead to:

• Disciplinary action, up to and including dismissal.

• Termination of subcontractor or supplier agreements.

• Reporting to relevant authorities, including law enforcement.

9.2 United Civils Limited will cooperate fully with any investigations by regulatory or enforcement bodies.

10: Training and Awareness

10.1 Induction for all staff will include a briefing on anti-bribery expectations.
10.2 Toolbox talks or updates will reinforce the zero-tolerance approach.
10.3 Supervisors and managers will receive guidance on identifying and addressing bribery risks.

11: Policy Review

11.1 This Policy will be reviewed annually or in response to significant changes in legislation, operations, or risk exposure.
11.2 Reviews will be conducted by SEHSS Limited and approved by Scott Bland.
11.3 Revisions will be communicated to all relevant personnel.

12: Legal and Regulatory Considerations

12.1 This Policy has been developed in accordance with the Bribery Act 2010 and guidance issued by the Ministry of Justice.
12.2 United Civils Limited commits to upholding legal and ethical standards in all commercial activities, including interactions with public and private sector clients.