Anti-Bribery and Corruption Policy

1. Policy Statement 

Plug and Play Limited, trading as Plug & Play Design ("the Company", "we", "us"), is committed to conducting business honestly, fairly, and ethically. We have a zero-tolerance approach to bribery and corruption in any form, whether committed by employees, contractors, or anyone acting on our behalf, anywhere in the world. 

This policy is intended to comply with the UK Bribery Act 2010, which applies to our conduct both in the UK and overseas, and to satisfy the requirement to maintain "adequate procedures" to prevent bribery under Section 7 of that Act. 

2. Purpose and Scope 

This policy applies to: 

• All directors, employees, and workers of Plug and Play Design Limited and Plug & Play Design, whether permanent, fixed-term, or temporary; 
• All contractors, freelancers, and consultants engaged by the Company, wherever they are based; 
• Any third party performing services for or on behalf of the Company, including agents, introducers, and business partners; 
• All business dealings and relationships, wherever they take place, in the UK and internationally. 

The purpose of this policy is to set out our commitment, explain what bribery and corruption are, and describe the standards and procedures we expect everyone acting for the Company to follow. 

3. What is Bribery? 

Bribery is offering, promising, giving, requesting, or accepting a financial or other advantage in order to induce or reward improper performance of a function or activity, or to secure an improper business advantage. Under UK law, bribery is a criminal offence, and it does not matter whether the advantage is given directly or through a third party, or whether it is cash, a gift, hospitality, a favour, or anything else of value. 

Bribery includes, but is not limited to: 

• Offering or giving a payment, gift, or other benefit to influence a business decision or gain an unfair advantage; 
• Requesting or accepting a payment, gift, or benefit in exchange for favourable treatment; 
• Bribing, or being bribed by, a foreign public official to obtain or retain business or a business advantage; 
• Facilitation payments: small unofficial payments made to secure or speed up routine government action (these are illegal under UK law even where locally tolerated). 

4. Our Commitment 

We commit to: 

• Never offering, giving, soliciting, or accepting a bribe, in any form, for any purpose; 
• Never making facilitation payments, regardless of local custom or perceived necessity; 
• Conducting proportionate due diligence on the third parties we engage to act on our behalf; 
• Maintaining clear, proportionate controls over gifts, hospitality, and expenses; 
• Encouraging employees, contractors, and suppliers to report any concerns without fear of reprisal; 
• Reviewing and improving this policy and our procedures on an ongoing basis. 

5. Gifts and Hospitality 

Reasonable and proportionate gifts and hospitality, given or received openly as part of normal business courtesy, are not prohibited. However, they must never be used, or appear to be used, to influence a business decision or secure an improper advantage. 

6. Charitable and Political Donations 

The Company does not make political donations.  

7. Third Parties and Due Diligence 

We are liable for bribery committed on our behalf by third parties, including agents, introducers, and subcontractors. Where we engage a third party to act on our behalf in business development, sales, or client introductions, particularly overseas or in higher-risk sectors, we will: 

• Conduct proportionate due diligence before engagement, appropriate to the level of risk; 
• Set out anti-bribery expectations in the engagement terms; 
• Avoid commission or fee structures that could incentivise improper conduct; 
• Reassess the relationship if credible bribery or corruption concerns arise. 

8. Raising Concerns 

Any employee, contractor, supplier, or other individual who has concerns or suspicions about actual or potential bribery involving the Company should raise this promptly. 

• Concerns can be raised, in confidence, with the Management Team 
• No individual will suffer any form of detriment or retaliation for raising a genuine concern in good faith, even if it later transpires that the concern was mistaken. 
• Concerns will be investigated promptly and appropriately, and escalated to the relevant authorities (for example the police or the Serious Fraud Office) where warranted. 

Employees and contractors must never attempt to investigate a suspected bribery matter themselves, and must not alert anyone suspected of being involved before raising the concern. 

9. Consequences of Breach 

Bribery is a criminal offence carrying, for individuals, up to 10 years' imprisonment and an unlimited fine, and for the Company, an unlimited fine and potential exclusion from public contracts. Any employee or contractor found to have breached this policy will face disciplinary action, up to and including dismissal or termination of contract, in addition to any legal consequences. 

For any further questions or clarifications regarding this policy, please contact [email protected]