1. Policy Statement
SoftTrain Cloud Ltd is committed to conducting its business in an honest and ethical manner. We have a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate.
We are fully committed to complying with the UK Bribery Act 2010 and all applicable anti-bribery and corruption laws.
2. Purpose of the Policy
This policy outlines our responsibilities regarding the prevention of bribery and provides guidance on how to recognise and deal with bribery and corruption. It aims to:
3. Scope of the Policy
This policy applies to all Directors and employees of SoftTrain Cloud Ltd and to any individuals or entities working on our behalf, including contractors, consultants, suppliers, partners, and agents.
4. What is Bribery?
Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action which is illegal, unethical, or a breach of trust. It can take many forms, including:
5. Prohibited Conduct
The following conduct is strictly prohibited:
6. Gifts and Hospitality
Gifts and hospitality must be reasonable, proportionate, and clearly not intended to influence a business decision. Any gift or hospitality above a modest value should be:
7. Responsibilities
All Directors, employees and any individuals acting on behalf of the company must:
8. Reporting Concerns
Suspected breaches or concerns relating to bribery or corruption should be reported directly to the Directors. Reports will be treated confidentially and investigated promptly.
9. Consequences of Non-Compliance
Breaches of this policy may result in:
10. Review and Approval
This policy is reviewed annually by the Directors to ensure its continued relevance and effectiveness. It may be updated at any time to reflect changes in the law or company practices.
11. Approval
This policy has been approved by the Directors of SoftTrain Cloud Ltd on 1st April 2025.
SoftTrain Cloud Ltd is committed to conducting its business in an honest and ethical manner. We have a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate.
We are fully committed to complying with the UK Bribery Act 2010 and all applicable anti-bribery and corruption laws.
2. Purpose of the Policy
This policy outlines our responsibilities regarding the prevention of bribery and provides guidance on how to recognise and deal with bribery and corruption. It aims to:
- Promote a culture of integrity and transparency;
- Set clear expectations for Directors, employees and third parties;
- Protect the reputation and interests of SoftTrain Cloud Ltd.
3. Scope of the Policy
This policy applies to all Directors and employees of SoftTrain Cloud Ltd and to any individuals or entities working on our behalf, including contractors, consultants, suppliers, partners, and agents.
4. What is Bribery?
Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action which is illegal, unethical, or a breach of trust. It can take many forms, including:
- Cash payments;
- Gifts, entertainment, or hospitality;
- Kickbacks or commissions;
- Favourable treatment or influence.
5. Prohibited Conduct
The following conduct is strictly prohibited:
- Offering, giving, soliciting, or accepting bribes of any kind;
- Making facilitation payments (small payments to speed up a process);
- Ignoring or turning a blind eye to suspicions of bribery.
6. Gifts and Hospitality
Gifts and hospitality must be reasonable, proportionate, and clearly not intended to influence a business decision. Any gift or hospitality above a modest value should be:
- Approved by the Directors;
- Clearly recorded.
7. Responsibilities
All Directors, employees and any individuals acting on behalf of the company must:
- Read and comply with this policy;
- Report any concerns or suspected bribery incidents;
- Maintain accurate records of all business dealings.
8. Reporting Concerns
Suspected breaches or concerns relating to bribery or corruption should be reported directly to the Directors. Reports will be treated confidentially and investigated promptly.
9. Consequences of Non-Compliance
Breaches of this policy may result in:
- Termination of business relationships;
- Internal disciplinary action;
- Legal action under the UK Bribery Act 2010.
10. Review and Approval
This policy is reviewed annually by the Directors to ensure its continued relevance and effectiveness. It may be updated at any time to reflect changes in the law or company practices.
11. Approval
This policy has been approved by the Directors of SoftTrain Cloud Ltd on 1st April 2025.