Introduction

Cleaning Masterclass is committed to conducting business ethically and in compliance with all applicable laws and regulations, including those that prohibit bribery and corruption. This Anti-Bribery Policy outlines our zero-tolerance approach to bribery and corruption and sets out our expectations for all employees, directors, officers, and third parties acting on our behalf.

Purpose and Scope

The purpose of this policy is to:

1. Set out our responsibilities, and the responsibilities of those working for us, in observing and upholding our position on bribery and corruption
2. Provide information and guidance to those working for us on how to recognize and deal with bribery and corruption issues
   This policy applies to all employees, directors, officers, and third parties acting on behalf of Cleaning Masterclass, in all countries where we operate.

Definition of Bribery

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal, unethical, or a breach of trust. Inducements can take the form of gifts, loans, fees, rewards, or other advantages (taxes, services, donations, etc.).

Policy Statement

Cleaning Masterclass prohibits:

1. The offering, promising, or giving of a bribe to any person or entity
2. The soliciting, accepting, or receiving of a bribe from any person or entity
3. The bribing of a foreign public official
4. The use of third parties to channel bribes to others

Employees must not engage in any form of bribery, either directly or through any third party.

Key Areas of Risk

1. Facilitation Payments – We do not make, and will not accept, facilitation payments of any kind.
2. Gifts and Hospitality – Giving or receiving gifts or hospitality is acceptable if it is reasonable, proportionate, and made in good faith. However, gifts and hospitality must not be given or received with the intention of influencing business decisions.
3. Political Contributions – We do not make contributions to political parties or candidates.
4. Charitable Donations – Charitable donations must not be used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices.

Employee Responsibilities

Employees must ensure that they read, understand, and comply with this policy. The prevention, detection, and reporting of bribery are the responsibility of all those working for us or under our control.
All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Record-Keeping

We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

How to Raise a Concern

Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage.

Protection

Individuals who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

Training and Communication

Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy.

Monitoring and Review

The directors will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible.

Consequences of Non-Compliance

Non-compliance with this policy may result in disciplinary action, including termination of employment, and may lead to criminal prosecution under relevant laws.