Anti-Bribery & Corruption Policy

Draft for client review

Status: Working draft dated 20 July 2026. This policy has been prepared from current official UK guidance for Bruce Penny to review. It is not yet an approved company policy.

Before approval, confirm that the responsibilities and working arrangements below match current practice. Professional legal or safety advice should be obtained where needed.

1. Purpose and scope

This policy applies to Penny Tree Surgery, its owner, workers, trainees, agency workers, subcontractors and any person acting on its behalf. We expect suppliers and business partners to follow equivalent standards where relevant to the work they carry out for us.

2. Our commitment

Penny Tree Surgery has zero tolerance for bribery and corruption. We will conduct business honestly, fairly and transparently, and we will not offer, promise, give, request or accept a financial or other advantage intended to induce or reward improper conduct.

Facilitation payments, kickbacks and secret commissions are prohibited. This applies whether the proposed benefit is offered directly or through another person.

3. Gifts, hospitality and charitable support

Reasonable and proportionate hospitality may be acceptable where it has a genuine business purpose and cannot reasonably be understood as an attempt to influence a decision. Cash gifts and cash equivalents must never be offered or accepted.

• Any gift or hospitality that could create a conflict, obligation or appearance of influence must be refused.
• Anything beyond normal low-value refreshments must be disclosed to Bruce Penny before it is accepted or offered.
• Donations and sponsorship must never be used to obtain an improper business advantage.

4. Working with others

We take a proportionate, risk-based approach when appointing subcontractors, agents and suppliers. This can include confirming identity, competence, reputation, ownership, payment arrangements and the reason for any unusual request.

No person acting for Penny Tree Surgery may make an unofficial payment, falsify an invoice, conceal the true purpose of a payment or use a third party to do something this policy prohibits.

5. Raising concerns and records

Suspected bribery, an improper request or a conflict of interest must be reported promptly to Bruce Penny. Concerns may also be raised under our Whistleblowing Policy. No worker will be penalised for raising a genuine concern in good faith.

Invoices, expenses, gifts and hospitality records must be accurate and sufficiently detailed to show the real purpose of the transaction. False, misleading or incomplete records are prohibited.

6. Responsibility, breaches and review

Bruce Penny has overall responsibility for this policy, proportionate bribery risk assessment, communication and review. A breach may lead to removal from a job, termination of a supplier or subcontractor relationship, disciplinary action where applicable, and referral to the police or another authority.

The policy will be reviewed at least annually and whenever the business, its customers, supply chain or bribery risks materially change.

7. Official guidance used

This draft follows the six principles in the Ministry of Justice guidance on the Bribery Act 2010: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.

Bribery Act 2010 guidance on GOV.UK