Ethics and Business Practices Policy

Last updated: 20 May 2026

Introduction

This Ethics and Business Practices Policy exists to set out the responsibilities of all staff in upholding the highest standards of professional conduct and impartiality in all affairs relating to Concentric Solutions (“the company”) and their role within the company.

Scope

All employees, visitors, customers, suppliers and contractors must abide by this policy. Those in senior or managerial positions or with specific responsibilities for recruitment, selection, training, appraisal and promotion should be especially mindful of the policy. Failure to comply with this policy could result in disciplinary action.

Policy Statement

Concentric Solutions is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure that bribery is prevented. The company has a zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, in whichever country we operate.

The duties of an employee or staff member are embodied in Common Law and built on by Statute. We are bound by the laws of the UK, including the Equality Act 2010, the Prevention of Corruption Acts 1906 and 1916, the Bribery Act 2010, the Criminal Finances Act 2017, and the Economic Crime and Corporate Transparency Act 2023, regardless of the geographic location in which we undertake the business of the company.

Concentric Solutions recognizes that bribery and corruption are punishable by imprisonment and fines. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, lose existing contracts and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal obligations seriously.

Who is covered by the policy?

This Ethics and Business Practices Policy applies to all members of staff (including temporary, agency, interim, contractor or consultant staff, trainees, permanent employees, seconded staff, home workers, our agents and representatives, or any other person or persons associated with us [including third parties], within Concentric Solutions or any subsidiary or affiliated business unit), regardless of location. The policy also applies to Officers, Directors and/or Managers of the business at all organisational levels.

In the context of this policy, ‘third parties’ refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisors or other third party official or public body.

Any arrangements our company makes with a third party are subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery, anti-corruption, fraud prevention, and the facilitation of tax evasion. All third-party arrangements are subject to their alignment with our accepted ethical and operating standards, and we reserve the right to terminate any arrangement where a third party is found to be in breach of these standards.

Definition of bribery

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Bribery is illegal. Staff must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent, distributor or partner). They must not bribe any official of any organisation or public body anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is deemed to be a bribe, a gift or an act of hospitality, they must seek further advice from the company’s HR Manager or a Director of the company.

The Bribery Act 2010 creates a specific standalone offence of bribing a foreign public official (Section 6). This offence applies regardless of whether the company has adequate anti-bribery procedures in place, as there is no equivalent corporate defence available as exists under Section 7. Any interaction with foreign public officials, whether in a commercial, contractual, or advisory capacity, must be reported to a Director of the company in advance wherever possible, and must under no circumstances involve any offer, gift, payment, or advantage intended to influence that official in their capacity as a public official.

Acceptable and unacceptable conduct

This section of the policy covers four areas:

a) Gifts and hospitality

b) Facilitation payments

c) Political contributions

d) Charitable contributions

Gifts and hospitality

Concentric Solutions accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

a) It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.

b) It is not made with the suggestion that a return favour is expected.

c) It is in compliance with local law.

d) It is given in the name of the company, not in an individual’s name.

e) It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).

f) It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).

g) It is of an appropriate type and value, given at an appropriate time, taking into account the reason for the gift.

h) It is given/received openly, not secretly.

i) It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.

j) It does not exceed £75 in value for physical gifts, or £150 per person for hospitality (including meals and events), as pre-determined by the company's Directors. These thresholds reflect proportionate and reasonable practice for a professional services consultancy. Director approval is required in writing before giving or receiving anything above these thresholds.

k) It is not offered to, or accepted from, a government official, public official, representative, politician, or political party without the prior written approval of a Director of the company. Given the heightened legal risk associated with public officials under the Bribery Act 2010, approval will only be granted in exceptional circumstances and must be documented.

l) A record of all gifts and hospitality given or received is maintained in the company gifts and hospitality register, held by the HR Manager. All gifts and hospitality must be declared regardless of value, and entries must include the date, nature, estimated value, and the parties involved.

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the HR Manager, who will assess the circumstances.

Concentric Solutions recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable may differ for each.

As good practice, gifts given and received should always be disclosed to the HR Manager. Gifts from suppliers should always be disclosed.

The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the HR Manager should be taken.

Facilitation payments and kickbacks

Concentric Solutions does not accept and will not make any form of facilitation payments of any nature. We recognize that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official or an officer of a third party in our favour to the extent that we secure or speed up the performance of their actions. Staff should also be aware that the Criminal Finances Act 2017 creates a separate corporate offence of failing to prevent the facilitation of tax evasion, and any arrangement that could be used to assist a client, supplier or third party in evading tax must be reported immediately to the HR Manager or a Director.

Concentric Solutions does not allow kickbacks to be made or accepted. We recognize that kickbacks are typically made in exchange for a business favour or advantage.

The company recognises that, despite our strict policy on facilitation payments and kickbacks, staff may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:

a) Keep any amount to the minimum.

b) Where possible, request a receipt, detailing the amount and reason for payment.

c) Create a record concerning the payment.

d) Report the incident to your line manager.

Political contributions

As a policy, Concentric Solutions will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognize this may be perceived as an attempt to gain an improper business advantage.

Charitable contributions

Concentric Solutions accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes in the name of the company.

Staff must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

Where charitable donations are made on behalf of the company, the recipient organisation should wherever possible be a registered charity, verifiable through the Charity Commission register. Donations to unregistered or unverifiable organisations must be documented with clear justification.

All charitable donations offered in the name of the company should be made in keeping with legal and ethical laws and practices. No donations by a member of staff shall be made on behalf of the company without the approval of the Directors.

Commissions and Referral Payments

Concentric Solutions recognises that the payment or receipt of commissions and referral fees is a legitimate part of commercial activity. However, such payments can be used as a vehicle for improper payments and must therefore be managed with care and transparency. All commission and referral fee arrangements must meet the following requirements:

a) They must be documented in a written agreement before any payment is made or received, setting out the basis, rate, and conditions of the commission or fee.

b) They must be proportionate to the service provided and reflect genuine market rates for the activity concerned.

c) They must be approved in advance by a Director of the company.

d) They must be paid through the company's normal commercial channels and recorded in the company's financial records.

e) They must not be structured in a way that could be used to conceal a bribe, facilitation payment, or any other improper payment.

No commission or referral fee shall be paid to a government official, public official, or their associates in any circumstances.

Staff Responsibilities

As a member of staff of Concentric Solutions, you must ensure that you read, understand, and comply with the information contained within this policy, and with any education or other anti-bribery or anti-corruption information that you are given.

All staff and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply a breach of this Ethics and Business Practices Policy.

If you 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, you must notify the HR Manager.

Staff must also be alert to any arrangement, transaction, or instruction that could facilitate the evasion of tax by a client, supplier, or third party. Under the Criminal Finances Act 2017, Concentric Solutions could face corporate criminal liability if it fails to prevent the facilitation of tax evasion by an associated person, regardless of whether the company itself was aware of or benefited from the arrangement. Any concerns must be reported immediately to the HR Manager or a Director.

Employees and staff members having official dealings with contractors and other suppliers or goods or services must avoid transacting any kind of private business with them by any means other than the company’s normal commercial channels. No favour or preferences as regards price, or otherwise, which is not generally available should be sought or accepted.

Outside interests including directorships, ownership, part ownership or material shareholdings in companies, businesses or consultancies likely to seek to do business with Concentric Solutions should be declared to the individual’s line manager, as should the interests of a spouse/partner or close relative, in the event that this may conflict with the interests of the company.

It is not the intention of the company, or this policy, to dissuade staff members from participating actively in public duties. It is important, however, that by doing so there is no suggestion to a third party that the staff member is acting on behalf of, or with the support of Concentric Solutions. To avoid any misunderstanding, no staff member should permit his or her company affiliation to be noted in any outside organisation’s materials or activities without the express written approval of a Director of the company.

Staff members should at all times conduct themselves in such a way as to protect and enhance the reputation of the company, its employees and business partners.

Staff should also be vigilant about fraud risks associated with emerging technologies, including artificial intelligence. This includes being alert to AI-generated impersonation, false representations, or manipulation of financial or contractual information, whether targeting Concentric Solutions or its clients.

If any staff member breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Concentric Solutions has the right to terminate a contractual relationship with a staff member if they breach this Ethics and Business Practices Policy.

Alerting the Company to a Concern

Concentric Solutions recognises and upholds the statutory protections afforded to whistleblowers under the Public Interest Disclosure Act 1998 (PIDA). Staff who make a qualifying disclosure in good faith are protected by law from dismissal, disciplinary action, or any other detriment as a result of making that disclosure. These protections apply regardless of the outcome of any subsequent investigation.

This section of the policy covers three areas:

1. How to raise a concern.
2. What to do if you are a victim of bribery, corruption or unethical behaviour.
3. Protection.

How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Concentric Solutions, or you are aware of unethical behaviour by others in respect of the business of Concentric Solutions, you are encouraged to raise your concerns at as early a stage as possible.

All concerns should be raised with the HR Manager, taking specific care to ensure the confidentiality of such notifications (written, verbal, electronic or otherwise). The HR Manager or a Director of the company will then progress an investigation and instigate appropriate action where such action is deemed necessary. Staff members shall keep their notifications to a manager or Director confidential in case such notifications cause a detrimental impact on the company’s investigation, or in case such matters under investigation are subsequently deemed not to contravene this Ethics and Business Policy.

If you are uncertain about whether a certain action or behaviour can be considered bribery, corrupt or unethical, you should speak to your line manager, the HR Manager or a Director of the company.

All cases of bribery, corruption or serious unethical behaviour will be dealt with as a disciplinary matter.

What to do if you are a victim of bribery, corruption or unethical behaviour

You must inform the HR Manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, or if you have reason to believe that you are a victim of another corrupt activity.

Protection

If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery, corruption or unethical behaviour, Concentric Solutions understands that you may feel at risk of potential repercussions. Concentric Solutions will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

The company will ensure that nobody 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, corruption or unethical behaviour.

Detrimental treatment refers to dismissal, disciplinary action, or unfavourable treatment in relation to the concern the individual has raised.

If you have reason to believe that you have been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager, the HR Manager or a Director of the company.

Education and Communication

Concentric Solutions will provide training on this policy as part of the induction process for all new employees or members of staff. All employees and staff members will also receive notification of any updates to this policy and will be asked annually to formally accept that they will comply with this policy. Training will also be provided to all staff when this policy is materially updated, and periodically thereafter as determined by the HR Manager.

Concentric Solutions’ Ethics and Business Practices Policy and zero-tolerance stance towards bribery, corruption and unethical behaviour will be clearly communicated to all suppliers, contractors, business partners and any third parties at the outset of business relations, and as appropriate thereafter.

Concentric Solutions will provide relevant information and education to staff members where the company feels that their knowledge of how to comply with this policy needs to be enhanced.

Record Keeping

Concentric Solutions will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. Each staff member shall declare all gifts and hospitality given or received, regardless of value, by recording them in the company gifts and hospitality register held by the HR Manager. Entries must include the date, nature, estimated value, and the parties involved. All gifts and acts of hospitality are subject to managerial review, and the register will be reviewed by a Director on a periodic basis.

Monitoring and Review

Concentric Solutions' HR Manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on an annual basis, or sooner if there are relevant changes in legislation or regulation. The review will assess the policy's suitability, adequacy and effectiveness against current requirements including the Bribery Act 2010, the Criminal Finances Act 2017, and the Economic Crime and Corporate Transparency Act 2023, and will take steps to update the policy where required. All updates will be recorded in the document history.

Internal control procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

Any need for improvements will be addressed promptly. Staff members are encouraged to offer their feedback on this policy if they have suggestions for how it may be further improved. All feedback should be addressed to the HR Manager.

This policy does not form a part of an employee’s contract of employment and Concentric Solutions may amend it at any time so as to improve its effectiveness at combatting bribery and corruption.