Anti Bribery & Corruption Policy Statement

Introduction

Bribery is, in the conduct of an organisation’s activity, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust.

Bribery is a criminal offence under The Bribery Act 2010.  Crystalcare Facilities Services Ltd prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by Crystalcare Facilities Services Ltd employees or by third parties acting for or on behalf of Crystalcare Facilities Services Ltd.

Offences

It is a criminal offence to:

• offer a bribe;

• accept a bribe;
• bribe a foreign official;
• as a commercial organisation, to fail to prevent a bribe.

You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. The Company could also face prosecution and be liable to pay a fine.

Purpose

The purpose of this policy is to convey to all employees and interested parties of Crystalcare Facilities Services Ltd the rules in relation to our unequivocal stance towards the eradication of bribery and our commitment to ensuring that the company conducts its business in a fair, professional and legal manner.

Scope

This policy applies to all employees of Crystalcare Facilities Services Ltd, regardless of seniority or site. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement. We will encourage application of this policy where our business involves external third parties.

Policy

It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for Crystalcare Facilities Services Ltd, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

It is also prohibited to act in the above manner in order to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.

If you are offered a bribe, or a bribe is solicited from you, or you suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you should not partake in these discussions unless your immediate safety is in jeopardy. You should immediately contact your senior manager so that action can be taken if considered necessary. You may be asked to give a written account of events.

Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.

Crystalcare Facilities Services Ltd will ensure that all of its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.

Crystalcare Facilities Services Ltd takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.

We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, or a contractor, etc.

Staff are reminded of the company’s Whistleblowing policy for reporting, which is available upon request.

Gifts and hospitality

We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.

Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans given or received as a mark of friendship or appreciation.

Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present.

No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from senior management.  Similarly, no gift nor offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving similar prior written approval.

A record will be made of every instance in which gifts or hospitality are given or received.

Other Aspects

1. Termination of Contracts with Business Partners in Breach

The company is committed to only engaging with business partners who uphold our strict anti-bribery standards. Where any business partner, contractor, or external third party acting on our behalf is found to be in breach of our Anti-Bribery & Corruption Policy. The company reserves the right to immediately terminate any contractual or business arrangement with the offending party. This measure will be enforced to maintain our ethical standards and to deter any future occurrences.

2. Continuous Improvement Based on Reported Cases

The company is dedicated to maintaining a robust anti-corruption programme. All incidents and cases reported under this policy will be periodically reviewed, and insights gained will be utilised to assess and improve our anti-corruption procedures. This continuous improvement approach ensures that any lessons learned from reported breaches are incorporated into our programme to strengthen our organisational resilience against bribery and corruption.

3. Reporting Breaches and Case Details to the Board of Directors

To ensure transparency and high-level oversight, all significant breaches of the Anti-Bribery & Corruption Policy, including case details, shall be reported to the Board of Directors on a quarterly basis. This reporting will cover the nature of the breach, individuals involved, corrective actions taken, and any improvements implemented in response. The Board will review these reports to ensure alignment with the company’s ethical standards and compliance requirements.

4. Assignment of Responsibility and Allocation of Resources

The company assigns primary responsibility for monitoring compliance with the Anti-Bribery & Corruption Policy to the Financial Director. The Financial Director shall ensure sufficient resources are allocated to maintain and oversee the effective implementation of this policy, including training, internal audits, and ongoing improvements to anti-bribery controls. Regular updates on compliance and any identified risks shall be provided to senior management and the Board of Directors as part of their oversight responsibilities.

This policy statement shall be made available to the public, upon request and subject to annual review to ensure its continued suitability.