Anti-Bribery & Corruption Policy

Introduction

We are committed to conducting all business activities with honesty, integrity and transparency.

CCR Recruitment Limited operates a zero-tolerance approach towards bribery, corruption, fraud and unethical business practices. We are committed to acting professionally, fairly and ethically in all business dealings and relationships and to implementing effective systems and controls to prevent bribery and corruption.

This Policy supports compliance with the Bribery Act 2010 and all applicable legislation relating to anti-bribery and anti-corruption.

Company Commitment

We are committed to this Policy and shall ensure it is communicated throughout our business and to all relevant stakeholders.

CCR Recruitment Limited expects the highest standards of ethical conduct from all employees, contractors, temporary workers, suppliers, subcontractors and business partners.

We will not offer, promise, give, request, agree to receive or accept any bribe or improper advantage, either directly or indirectly, for the purpose of obtaining or retaining business or securing an unfair business advantage.

Scope of the Policy

This Policy applies to:

• Directors
• Employees
• Temporary workers
• Agency workers
• Contractors
• Consultants
• Suppliers
• Subcontractors
• Business partners
• Any person acting on behalf of CCR Recruitment Limited

The Policy applies to all business activities undertaken in the United Kingdom and internationally.

Prohibited Conduct

Individuals must not:

• Offer, promise or provide a bribe
• Request, agree to receive or accept a bribe
• Make facilitation payments or unofficial payments
• Offer gifts, hospitality or benefits intended to influence business decisions improperly
• Use company funds or resources for corrupt purposes
• Conceal, falsify or misrepresent financial records
• Engage in any activity that may create an actual or perceived conflict of interest

Bribery may take many forms, including:

• Cash payments
• Gifts
• Entertainment
• Travel expenses
• Employment opportunities
• Commissions
• Discounts
• Personal favours
• Other financial or non-financial advantages

Gifts and Hospitality

We recognise that reasonable and proportionate hospitality may form part of legitimate business relationships.

However, gifts or hospitality must:

• Be reasonable, proportionate and transparent
• Comply with applicable laws and regulations
• Not influence or appear to influence business decisions
• Not create an obligation or expectation of preferential treatment
• Be accurately recorded where appropriate

Cash gifts or cash equivalents must never be offered or accepted.

Any gift or hospitality considered excessive or inappropriate must be declined.

Recruitment and Business Relationships

As a recruitment business, we recognise the importance of maintaining ethical relationships with:

• Clients
• Candidates
• Labour suppliers
• Subcontractors
• Professional advisers
• Supply chain partners

We shall ensure that business decisions are based solely on legitimate commercial considerations and not influenced by improper payments, incentives or benefits.

Due Diligence Processes

We shall:

• Conduct appropriate due diligence on suppliers, contractors and business partners
• Assess bribery and corruption risks associated with business activities
• Implement financial controls designed to prevent improper payments
• Maintain accurate accounting and business records
• Require suppliers and contractors to comply with applicable anti-bribery legislation
• Investigate concerns regarding unethical conduct
• Take corrective action where breaches are identified
• Review our controls periodically to ensure effectiveness

Training and Awareness

We shall:

• Promote awareness of anti-bribery and anti-corruption requirements
• Provide appropriate guidance and instruction to relevant personnel
• Ensure management understands its responsibilities under this Policy
• Encourage a culture of integrity and ethical business conduct

Reporting Concerns

We encourage employees, candidates, clients, suppliers and contractors to report any concerns relating to:

• Bribery
• Corruption
• Fraud
• Improper payments
• Conflicts of interest
• Financial misconduct
• Any breach of this Policy

Reports should be made to the Managing Director or a designated member of management.

All concerns will be investigated appropriately and confidentially wherever possible.

Whistleblowing Protection

Individuals who raise genuine concerns in good faith will be protected from retaliation, victimisation or adverse treatment.

CCR Recruitment Limited is committed to maintaining an open and transparent reporting culture.

Breaches of this Policy

Any breach of this Policy may result in:

• Disciplinary action
• Termination of employment or engagement
• Termination of supplier or contractor relationships
• Referral to law enforcement or regulatory authorities where appropriate

Policy Review

This Policy shall be reviewed periodically to ensure continued compliance with legislation, industry standards and best practice.

The above processes are designed to:

• Prevent bribery and corruption within our business operations
• Promote ethical and transparent business conduct
• Protect the reputation of CCR Recruitment Limited
• Support compliance with the Bribery Act 2010
• Maintain trust with clients, candidates, suppliers and stakeholders