Anti-Bribery Policy for Your Recruiters Limited

1. Introduction

Your Recruiters Limited (“the Company”) is committed to conducting all business with integrity and in compliance
with the law. This includes ensuring adherence to the UK Bribery Act 2010, which prohibits bribery and corruption
in all forms.

This policy applies to all employees, contractors, consultants, and anyone acting on behalf of the Company.

2. Purpose

• The purpose of this policy is to:
  
  Set out the Company’s responsibilities in preventing bribery and corruption.
  Provide guidance to employees and stakeholders on recognizing and avoiding situations that could lead to
  bribery or corruption.
  Protect the Company from reputational damage and legal liability.

3. Definitions

Bribery: Offering, promising, giving, accepting, or soliciting something of value as an inducement for improper
action or decision-making.

Corruption: Abuse of power for personal or organisational gain.

Facilitation Payments: Small, unofficial payments to expedite routine processes.

4. Policy Statement

Your Recruiters Limited prohibits:

• Offering, giving, soliciting, or accepting bribes in any form.
• Making facilitation payments or engaging in corrupt practices.
• Indirect bribery through third parties, agents, or partners.

5. Responsibilities

5.1. Management

The Board of Directors and senior management are responsible for ensuring compliance with this policy and implementing procedures to minimise the risk of bribery.

5.2. Employees

All employees must:

• Read and understand this policy.
• Report any suspicions of bribery or corruption immediately.
• Refuse to participate in any form of bribery, even if it results in a loss of business.

6. Gifts, Hospitality, and Expenses

The Company recognises that modest gifts and hospitality can foster good business relationships. However, they
must never be given or received with the intent to influence decisions improperly.

Permissible Gifts and Hospitality:

• Must be reasonable and proportionate.
• Must not exceed £50 in value without prior approval.

All gifts and hospitality must be declared and recorded in the Company’s Gift and Hospitality Register.

7. Reporting and Whistleblowing

Employees are encouraged to report concerns or suspicions of bribery confidentially and without fear of
retaliation. Reports can be made to:

• The Compliance Officer (administration@your-recruiters.co.uk).
• The Whistleblowing Hotline: 0116 467 0800
• The Company will investigate all reports promptly and take disciplinary action where necessary.

8. Training and Awareness

The Company will provide training on this policy to ensure all employees understand their responsibilities and the
risks of bribery.

9. Monitoring and Review

This policy will be reviewed annually to ensure effectiveness and compliance with legal requirements.

10. Consequences of Breach

Any employee found to be involved in bribery or corruption will face disciplinary action, up to and including
dismissal, and may also be reported to law enforcement.

11. Contact Information

For questions about this policy or to report a concern, contact:

Michael Clapton
Joint Managing Director & Compliance Officer
Your Recruiters Limited
Email: michael.clapton@your-recruiters.co.uk
Phone: 0116 467 0800

Approved by The Board of Directors on 01/05/2024