Anti-Bribery & Corruption Policy

Stravica Ltd has a strict zero tolerance approach to bribery and corruption across all activities and supply chains. We comply with the Bribery Act 2010 and related UK laws and operate proportionate controls, training, and audit to protect our people, our clients, and the public purse.

What this means in practice

• No bribes, ever
  We forbid offering, giving, requesting, or accepting any advantage intended to influence a decision or secure an improper benefit. This applies to everyone who works for us or represents us.
   
• Gifts and hospitality
  Allowed only when modest, infrequent, clearly for a legitimate business purpose, and recorded.
  • Token items up to £30: generally acceptable.
  • £31 to £100: line manager approval and entry in the Gifts and Hospitality Register.
  • Over £100 or any travel, accommodation or entertainment: advance approval from the Head of Governance and Compliance.
  • Any interaction with public officials: advance approval is required at any value.
  Cash or cash equivalents are never permitted.
   
• No facilitation payments or kickbacks
  We do not make small unofficial payments to speed up routine actions or accept any form of rebate for awarding work. If personal safety would be at risk, keep any unavoidable payment to the minimum, record it, and report it to Compliance within 24 hours.
   
• Political and charitable activity
  No political donations. Charitable donations and sponsorships are permitted only after due diligence and approval. Payments are made to verified accounts and are reported transparently.
   
• Conflicts of interest
  Personal interests that could influence decisions must be declared immediately. Mitigations are recorded in the Conflicts Register.
   
• High risk situations
  Extra controls apply to procurement and subcontracting, tender periods, use of agents or intermediaries, cash handling, and work in higher risk countries. All third parties must meet the same standards and accept audit rights.
   
• Financial records
  All transactions are complete, accurate, approved, and auditable. No off-book funds or accounts.
   
• Training and certification
  All staff complete induction and annual refresher training. High risk roles receive additional workshops. Key suppliers sign our Supplier Integrity Commitment.
   
• Speak up safely
  Concerns can be raised confidentially and without fear of retaliation:
  • Line Manager
  • Head of Governance and Compliance at compliance@stravica.uk