Anti-Bribery & Anti-Corruption Policy
Last updated: 01.01.2026
CAE Business Solutions Ltd (“the Company”) is committed to conducting its business in an honest, ethical, and transparent manner. The Company maintains a zero-tolerance approach to bribery and corruption and is committed to acting professionally and with integrity in all business dealings.
This policy sets out the principles and procedures implemented by the Company to prevent bribery and corruption and to ensure compliance with the UK Bribery Act 2010 and other applicable legislation.
1. Purpose of This Policy
The purpose of this policy is to:
- prevent bribery and corruption within the Company’s operations
- ensure compliance with the UK Bribery Act 2010
- promote a culture of ethical business conduct
- protect the Company’s reputation and integrity
- ensure transparency in relationships with clients, suppliers, and partners.
2. Scope of This Policy
This policy applies to all individuals working for or on behalf of the Company, including:
- employees
- directors
- consultants and contractors
- freelancers
- suppliers and service providers where applicable.
All individuals associated with the Company are expected to comply with the principles set out in this policy.
3. Definition of Bribery
Bribery is defined as offering, promising, giving, requesting, or accepting an advantage in order to influence the behaviour of another person in the performance of their duties.
A bribe may include:
- money or financial payments
- gifts or hospitality
- services or favours
- employment opportunities
- preferential treatment.
Bribery may occur in both public and private sector transactions.
4. Prohibited Conduct
The following actions are strictly prohibited:
- offering or giving a bribe to influence a business decision
- requesting or accepting a bribe from another party
- offering anything of value to secure an unfair business advantage
- facilitating corrupt practices through intermediaries or third parties.
The Company strictly prohibits any activity that could be interpreted as bribery or corruption.
5. Facilitation Payments
Facilitation payments are unofficial payments made to secure or expedite routine governmental or administrative actions.
Such payments are illegal under the UK Bribery Act 2010 and are strictly prohibited by the Company.
Employees or representatives must not make or authorise facilitation payments under any circumstances.
6. Gifts and Hospitality
The Company recognises that reasonable business hospitality may be appropriate in certain circumstances.
However, gifts or hospitality must:
- be reasonable and proportionate
- not be intended to influence business decisions
- comply with applicable laws and regulations
- be transparent and properly recorded where appropriate.
Excessive or inappropriate gifts or hospitality are not permitted.
7. Conflicts of Interest
Individuals associated with the Company must avoid situations where personal interests could conflict with the interests of the Company.
Where potential conflicts arise, they must be disclosed promptly so that appropriate action can be taken.
8. Due Diligence and Third Parties
The Company seeks to engage reputable suppliers, partners, and contractors who operate in accordance with ethical business practices.
Where appropriate, the Company may carry out reasonable due diligence when entering into business relationships.
Third parties working with the Company are expected to uphold the same standards of integrity and compliance.
9. Reporting Concerns
Any individual associated with the Company who becomes aware of suspected bribery or corruption must report the matter promptly.
Reports will be treated seriously and investigated appropriately.
The Company encourages the reporting of genuine concerns without fear of retaliation.
10. Consequences of Non-Compliance
Failure to comply with this policy may result in disciplinary action, termination of contracts, or other appropriate measures.
Where necessary, suspected illegal activities may be reported to the relevant authorities.
11. Monitoring and Review
The Company will review this policy periodically to ensure that it remains effective and aligned with legal requirements and best practices.
12. Commitment
CAE Business Solutions Ltd is committed to maintaining the highest standards of ethical conduct and integrity in all business activities.
All individuals associated with the Company are expected to support this commitment and conduct themselves in a manner consistent with this policy.