Anti‑Bribery and Corruption Policy

Circulayo is committed to conducting business ethically and lawfully. We have zero tolerance for bribery, corruption, facilitation payments, kickbacks and fraudulent behaviour. This policy applies to all employees, contractors, consultants, agents and any third parties acting on our behalf.

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Key principles:

• Compliance with the UK Bribery Act 2010 and other applicable anti‑corruption laws.

• Prohibition on offering, giving, requesting or receiving bribes or facilitation payments in any form.

• Gifts, hospitality and entertainment must be modest, infrequent and not intended to influence business decisions. All gifts and hospitality above a specified threshold must be recorded and approved.

• Third‑party risk management: due diligence must be conducted on agents, suppliers and partners to ensure they adhere to anti‑corruption standards.

• Employees must report any suspicions of bribery or corruption to management or via the whistleblowing process. Violations will result in disciplinary action and may be reported to authorities.

 

This policy aligns with our Code of Business Conduct and Compliance Policy. Training will be provided to relevant personnel, and we will review and update this policy periodically.