Anti-Bribery and Corruption Policy

Our zero-tolerance position on bribery, corruption and the facilitation of financial crime.

Document control
Reference	AM-POL-005
Version	1.0
Classification	Public
Owner	James Peachey, Co-founder
Approved by	James Peachey, Co-founder, on 2 June 2026
Next review	2 June 2027
Applies to	All amarti employees, contractors and associates
Standards alignment	Bribery Act 2010; Criminal Finances Act 2017; ISO 9001:2015

1. Policy statement

amarti has zero tolerance for bribery and corruption. We win work on the strength of our people and our delivery, not on inducements.

We are committed to acting professionally, fairly and with integrity in all our business dealings, wherever we operate. We will uphold all laws relevant to countering bribery and corruption, in particular the Bribery Act 2010.

Bribery is a criminal offence. An individual convicted of bribery can face an unlimited fine and up to ten years’ imprisonment. A company that fails to prevent bribery by an associated person commits a separate corporate offence under section 7 of the Bribery Act 2010 and can face an unlimited fine, confiscation of profits and exclusion from public procurement. amarti would also face serious and lasting reputational damage.

2. Scope

This policy applies to everyone who performs services for or on behalf of amarti: employees, co-founders, contractors, associates, agents, introducers and any other third party acting in our name. Everyone in scope is responsible for reading, understanding and complying with it.

It applies to all our business activity, in the UK and overseas, and to dealings with both private sector clients and public officials.

3. What is prohibited

You must not, directly or through a third party:

• Offer, promise, give, request, agree to receive or accept a financial or other advantage intended to induce or reward the improper performance of a function or activity, or to influence a public official in the performance of their duties.
• Make or accept a facilitation payment: a small unofficial payment made to secure or speed up a routine action. These are bribes and are prohibited without exception, even where they are common practice locally.
• Offer or accept a kickback: a payment made in return for a business favour or advantage, such as the award of a contract or the placement of a consultant.
• Threaten or retaliate against anyone who has refused to commit a bribery offence or who has raised a concern under this policy.
• Engage in, or knowingly facilitate, tax evasion by another person. Under the Criminal Finances Act 2017 a company commits an offence if an associated person criminally facilitates tax evasion and the company did not have reasonable prevention procedures in place. This offence applies to businesses of every size, including amarti.
• Take part in any other form of corruption, including fraud, money laundering or the deliberate misstatement of records.

4. Gifts and hospitality

amarti recognises that reasonable and proportionate hospitality is a normal part of building business relationships. It is not prohibited. It becomes a problem when it is intended, or could reasonably be seen as intended, to influence a business decision.

Gifts and hospitality are acceptable where they are:

• Given or received openly, in amarti’s name rather than to an individual personally, and not concealed.
• Reasonable and proportionate in value and frequency, and appropriate to the relationship.
• Not cash or a cash equivalent such as a gift card or voucher.
• Not offered or accepted during a live tender, bid, contract renewal or supplier selection process.
• Compliant with the recipient organisation’s own rules. Check first, particularly with public sector clients, who often prohibit acceptance entirely.

Value of gift or hospitality	What you must do
Up to £50	Use your judgement against the tests above. No approval or entry needed.
£50 to £150	Obtain approval from James Peachey before offering or accepting, and record it in the Gifts and Hospitality Register.
Over £150	Normally declined. Approval from James Peachey is required in advance and must be recorded with the reason.
Any amount, involving a public official	Obtain approval from James Peachey in advance regardless of value, and record it.

The Gifts and Hospitality Register is maintained by James Peachey and reviewed at each quarterly leadership review. Where a gift cannot reasonably be refused without causing offence, accept it, declare it immediately, and hand it to James so it can be donated or shared.

5. Donations, sponsorship and political activity

amarti does not make political donations of any kind. Charitable donations and sponsorship are permitted where the recipient is a legitimate registered charity or organisation, the payment is properly recorded, and it is not made to secure a business advantage or at the request of a client or prospective client. All such payments require approval from James Peachey.

6. Working with third parties

The greatest bribery risk for a consultancy of our size sits with third parties who act on our behalf: introducers, agents, resellers and subcontracted associates. Before engaging any third party who will represent amarti commercially, we will:

• Carry out proportionate due diligence, including identity and ownership checks and adverse media screening where the engagement is in a higher-risk market or sector.
• Ensure the commission or fee is commercially justifiable and proportionate to the service actually provided.
• Include an anti-bribery clause in the contract giving amarti a right to terminate for breach.
• Pay only to a bank account in the name of the contracting party, in the country where the service was performed, and only against a proper invoice.

Due diligence is coordinated with the checks set out in the Supplier Relationship Policy (AM-POL-007).

7. Record keeping

All accounts, invoices, expense claims and other records relating to dealings with third parties must be prepared and maintained accurately and completely. No accounts may be kept off-book. Expense claims relating to gifts, hospitality or payments to third parties must state the reason for the expenditure and who benefited.

8. Raising a concern

If you are offered a bribe, asked to make one, suspect that bribery or corruption may have occurred, or are simply unsure whether something is acceptable, raise it as soon as possible with James Peachey (james@amarti.io). If the concern involves James, raise it with Ben Alexander (ben@amarti.io) or Amardeep Sirha (amardeep@amarti.io).

amarti will support anyone who raises a genuine concern in good faith, even if it turns out to be mistaken. You will not suffer any detriment as a result. Workers who make a protected disclosure are also protected by the Public Interest Disclosure Act 1998. Concerns will be treated confidentially so far as is possible, and you may raise a concern anonymously, although this may limit how far we can investigate.

Any employee who breaches this policy faces disciplinary action up to and including summary dismissal for gross misconduct under the Disciplinary Policy and Procedure (AM-POL-004). Any contractor, associate or third party who breaches it faces immediate termination of their engagement.

9. Responsibilities, monitoring and review

James Peachey, Co-founder, is accountable for this policy, maintains the Gifts and Hospitality Register, approves exceptions and investigates concerns raised.

Ben Alexander, Co-founder, is responsible for applying this policy in sales, bid and introducer relationships, and for ensuring bid teams understand the rules around hospitality during live procurements.

All amarti people complete anti-bribery awareness as part of induction and refresher training at least every two years.

This policy is reviewed at least annually by the leadership team, and the risk assessment underpinning it is refreshed whenever we enter a new market or a materially different type of engagement.

amarti follows the six principles of adequate procedures published by the Ministry of Justice: proportionate procedures, top-level commitment, risk assessment, due diligence, communication including training, and monitoring and review. We also note the corporate offence of failure to prevent fraud under the Economic Crime and Corporate Transparency Act 2023. Although amarti currently falls below the size thresholds for that offence, we apply the same preventative principles.

Questions about this document

The first point of contact for this document is James Peachey (james@amarti.io). Where a query is best handled by another member of the leadership team, it will be routed as follows:

Contact	Area	Email
Ben Alexander, Co-founder	Sales, client engagement and consultant operations	ben@amarti.io