Anti-Bribery Policy
Last updated: February 2026
1. Zero Tolerance Statement
Brity Group Limited trading as Brity operates a zero-tolerance policy towards bribery and corruption in all its forms. We are committed to conducting our business fairly, honestly, and with integrity.
We comply with the UK Bribery Act 2010 and all applicable anti-corruption laws in the jurisdictions in which we operate. This policy applies to all business dealings and transactions in all countries where we conduct business.
Bribery and corruption undermine legitimate business activities, distort competition, and cause serious reputational and legal harm. We will not engage in any form of bribery, whether directly or through third parties, and we expect all those associated with our business to uphold these standards.
2. Scope
This policy applies to:
- All directors, officers, and employees of Brity Group Limited
- All freelance and associate trainers delivering courses on our behalf
- All contractors, consultants, and agents acting for or on behalf of the company
- Any other persons or entities associated with our business
This policy covers all business dealings, including interactions with public bodies (such as local councils, NHS trusts, and government departments), corporate clients, awarding bodies, and certification organisations.
3. Definitions
Understanding what constitutes bribery is essential for compliance:
Offering, promising, giving, requesting, or accepting a financial or other advantage to induce or reward improper performance of a function or activity, or where the acceptance itself constitutes improper performance.
The abuse of entrusted power for private gain. This includes but is not limited to bribery, extortion, fraud, and nepotism.
Small, unofficial payments made to secure or expedite routine actions by public officials. These are illegal under UK law and strictly prohibited.
A portion of a payment returned to the payer or a third party as a reward for facilitating a transaction. These are strictly prohibited.
4. Guiding Principles
All personnel must adhere to the following principles:
- Never offer, promise, give, or accept any bribe or other improper advantage
- Never make facilitation payments or "grease payments"
- Never engage in any activity that could lead to a breach of this policy
- Always act in the best interests of the company and maintain high ethical standards
- Report any suspected or actual breaches of this policy immediately
- Seek guidance when uncertain about whether an action could constitute bribery
Facilitation payments are strictly prohibited, regardless of local custom or pressure. There are no exceptions to this rule. If you are asked to make such a payment, you must refuse and report the request immediately.
Be alert to the following warning signs that may indicate bribery or corruption:
- Requests for unusual payment methods (cash, offshore accounts, third parties)
- Gifts offered during procurement, tender, or contract negotiations
- A supplier insisting on using a particular consultant without clear justification
- Unexplained payment requests from a third party or intermediary
- Pressure to approve invoices without proper supporting documentation
- Requests for unusually large commissions or fees
- Reluctance to provide written records of agreements
Under the UK Bribery Act 2010, an individual guilty of an offence can face up to 10 years' imprisonment and/or an unlimited fine. The company can face an unlimited fine and reputational damage.
5. Gifts & Hospitality
Modest gifts and hospitality can be a legitimate part of building business relationships. However, they can also be used improperly. The following rules apply:
- Modest gifts of low value (under £50)
- Normal business hospitality (coffee, lunch)
- Branded promotional items
- Gifts at Christmas or religious festivals (if modest)
- Cash or cash equivalents (vouchers, gift cards)
- Lavish or extravagant hospitality
- Gifts during a tender or procurement process
- Anything intended to influence a decision
- Gifts or hospitality over £50 must be pre-approved by the Chief Executive Officer
- All gifts given or received over £25 must be recorded in the Gifts & Hospitality Register
- Any gift or hospitality to/from public sector employees requires prior approval
Even if a gift is under £50, it must be refused if it could reasonably be seen to influence a business decision. When in doubt, decline the gift and seek guidance from the Chief Executive Officer.
6. Conflicts of Interest
A conflict of interest arises when personal interests interfere, or could appear to interfere, with professional judgement or the interests of the company.
Examples of potential conflicts include:
- Having a financial interest in a competitor, supplier, or customer
- Employment or consultancy with a competitor or related business
- Personal relationships with clients, suppliers, or their employees
- Ownership of, or investment in, businesses that deal with Brity Group Limited
- Awarding contracts or business to family members or close friends
All actual or potential conflicts of interest must be disclosed to the Chief Executive Officer immediately. Failure to disclose a conflict is a breach of this policy. Disclosed conflicts will be managed appropriately to protect the integrity of business decisions.
7. Third Parties & Subcontractors
We may be held responsible for acts of bribery committed by those acting on our behalf. This includes freelance trainers, agents, consultants, and other third parties.
Before engaging any third party, we will:
- Conduct appropriate due diligence proportionate to the risk
- Ensure contracts include anti-bribery obligations and the right to terminate for breach
- Provide relevant training and awareness materials
- Monitor performance and compliance where appropriate
High-risk third parties (e.g., those with public sector contacts, overseas agents, or intermediaries) must be approved by the Chief Executive Officer before engagement. Enhanced due diligence will be conducted on such parties.
All associate and freelance trainers must acknowledge and agree to comply with this policy as part of their engagement. They must not offer any inducement to gain certification outcomes, booking preferences, or favourable assessments for learners.
8. Reporting Concerns
We encourage all personnel to report any concerns about suspected bribery or corruption. This includes concerns about:
- Actual or suspected bribery or corruption
- Attempts by others to bribe or corrupt our personnel
- Concerns about the conduct of third parties acting on our behalf
- Weaknesses in our anti-bribery controls
- Attempts to discourage or prevent the reporting of concerns
Reports can be made to the Chief Executive Officer in person, by phone, or by email. All reports will be treated confidentially and investigated appropriately.
Email: info@brity.co.uk
Anyone who reports a genuine concern in good faith will be protected from any form of retaliation. We will not tolerate any attempt to victimise or disadvantage anyone who raises a concern. Raising a malicious or false allegation, however, may result in disciplinary action.
9. Disciplinary Consequences
Any breach of this policy is a serious matter and will be dealt with accordingly.
- Employees: Disciplinary action up to and including summary dismissal for gross misconduct
- Freelance Trainers: Immediate termination of engagement and removal from our register
- Third Parties: Termination of contract and exclusion from future business
- All Parties: Potential criminal prosecution and civil liability
We will report any suspected criminal activity to relevant regulators and authorities, including the Serious Fraud Office, National Crime Agency, and police where appropriate. We will cooperate fully with any investigation.
10. Record Keeping
We maintain accurate and complete records of all business transactions. This includes:
- Financial records that accurately reflect all transactions
- Gifts & Hospitality Register
- Conflicts of Interest declarations
- Due diligence records for third parties
- Records of anti-bribery training provided
- Records of any concerns raised and investigations conducted
These records are retained in accordance with our data retention policy and may be subject to audit or review.
We reserve the right to audit third party compliance records where appropriate. Our contracts with third parties include provisions for such audits, and refusal to cooperate may result in termination of the business relationship.
11. Training & Awareness
We are committed to ensuring all relevant personnel understand their responsibilities under this policy:
- All new employees and trainers receive anti-bribery training as part of induction
- Refresher training is provided periodically and when this policy is updated
- Additional training is provided to those in higher-risk roles
- This policy is readily available to all personnel
Training records are maintained and training effectiveness is reviewed regularly.
12. Review
This policy is reviewed annually, or earlier where triggered by regulatory, operational, or organisational change.
This policy has been approved by the Chief Executive Officer of Brity Group Limited.
Questions or Concerns?
Concerns about potential bribery or corruption should be reported via the Whistleblowing Policy process, which provides protected disclosure safeguards.
For general policy enquiries, please contact:
Email: info@brity.co.uk
Policy Owner: Chief Executive Officer
Next Review Due: January 2027
Version: 2
Date of Publication: 26 February 2026