1. Policy Statement
1.1 At Elezi Construction and its subsidiary companies, we conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, implementing and enforcing effective systems to counter bribery and corruption.

1.2 We take our legal responsibilities very seriously. We will uphold all laws relevant to countering bribery and corruption, including the UK Bribery Act 2010, in respect of our conduct both at home and abroad.

2. About this Policy
2.1 The purpose of this policy is to:
(a) Outline our responsibilities and those working on our behalf in observing and upholding our anti-bribery position; and
(b) Provide information and guidance to those working for and on our behalf on recognising and dealing with bribery and corruption.

2.2 This policy does not form part of any contract of employment or contract for services, and we may amend it at any time.

3. Who does this policy apply to?
3.1 This policy applies to everyone working for or on behalf of Elezi Construction in any capacity – including employees, directors, officers, agency staff, interns, consultants, contractors, third-party representatives, sponsors, and business partners, wherever located.

4. Who is responsible for this policy?
4.1 The Board of Directors holds overall responsibility for the effective implementation of this policy. The Finance Director serves as Compliance Officer at Board level and delegates oversight to the Quality & Compliance Manager.

4.2 The HR Department manages day-to-day responsibilities. Direct questions to HR, who will involve the Compliance Manager where appropriate.

5. Definitions
5.1 Bribery is offering, promising, giving, or accepting any financial or other advantage to induce or reward improper performance.
(a) An advantage may include gifts, loans, cash, hospitality, discounts, contracts, or anything else of value.
(b) Improper acts violate law, ethics, or duties of trust.

5.2 Corruption is the abuse of power or position for personal gain.
Examples:
Offering a bribe (e.g., sports tickets in return for business).
Receiving a bribe (e.g., securing a job for a relative in exchange for business).
Bribing foreign officials (e.g., facilitation payments to speed up customs).

5.3 Facilitation payments are unofficial small payments to speed up services.
5.4 Kickbacks are payments given in return for a business favor.
5.5 Third parties include clients, suppliers, agents, government officials, and any business contact encountered while working with or for us.

6. Identifying Risks
6.1 As a company operating in a high-risk sector, we have strengthened our due diligence, procurement procedures, and provided staff training to mitigate risks.

7. What You Must Not Do
It is unacceptable to:
Offer or accept bribes.
Give/receive gifts that influence business decisions.
Make facilitation payments.
Offer gifts to government officials without approval.
Retaliate against whistleblowers.

8. Facilitation Payments and Kickbacks
8.1 These are strictly prohibited.
8.2 Always request receipts and ensure transparency. Report any concerns to the Compliance Manager.

9. Gifts, Hospitality and Expenses
9.1 Reasonable and proportionate gifts/hospitality are allowed for building business relationships and enhancing reputation.
9.2 Gifts must:
Not influence decisions.
Be given in the company's name.
Not involve cash.
Be appropriate, timely, and transparent.
Comply with local laws.

9.3 Low-value branded gifts are usually acceptable.
9.4 Expense reimbursements must be genuine and reasonable.
9.5 Apply a test of reasonableness and intent to any gift or payment.

10. Donations
10.1 We do not contribute to political parties.
10.2 Charitable donations must be approved and ethical.

11. Record-Keeping
11.1 Maintain proper financial records for third-party payments.
11.2 Declare and record all gifts/hospitality over £250.
11.3 Submit expense claims in accordance with policy.
11.4 Ensure records are accurate and complete – no “off-book” accounts allowed.

12. Your Responsibilities
12.1 Understand and follow this policy.
12.2 Prevent, detect, and report any bribery or corruption.
12.3 Notify the Compliance Officer if you suspect a conflict or breach.

13. Raising Concerns
13.1 Report any bribery suspicions to the Compliance Officer promptly.
13.2 Seek advice if unsure whether something is bribery.

14. Protection
14.1 We support whistleblowers acting in good faith.
14.2 Report any retaliation to the Compliance Officer or raise formally via the Grievance Procedure.

15. Training and Communication
15.1 This policy is part of all staff induction, with refresher training provided.
15.2 Suppliers and contractors will be informed of our zero-tolerance stance.

16. Breaches of Policy
16.1 Breaching this policy may result in disciplinary action, including dismissal.
16.2 Relationships with non-compliant third parties may be terminated.