Anti-Bribery and Corruption Policy

1. Purpose 

This policy outlines Forfront’s commitment to preventing bribery and corruption in all aspects of its operations. It is designed to comply with the Bribery Act 2010 and reflects our zero-tolerance approach to bribery and corrupt practices. 

2. Scope 

This policy applies to all employees, officers, contractors, consultants, agents, and any other third parties acting on behalf of Forfront Ltd, regardless of location. 

3. Policy Statement 

Forfront strictly prohibits: 

  • Offering, giving, requesting or receiving bribes in any form. 

  • Making facilitation payments or unofficial payments to public officials. 

  • Giving or accepting gifts or hospitality with the intention of influencing business decisions. 

  • Engaging in corrupt practices, whether directly or indirectly. 

Bribery is a criminal offence and can result in severe penalties, including imprisonment and unlimited fines. The company may also face reputational damage and regulatory consequences. 

4. Definitions 

Bribe: A financial or other advantage offered, promised, or given to induce or reward the improper performance of a function or activity. 

Facilitation Payment: A small, unofficial payment made to secure or speed up a routine action. 

Third Party: Any individual or organisation the company engages with, such as suppliers, partners, or intermediaries. 

5. Gifts and Hospitality 

Reasonable and proportionate gifts and hospitality may be accepted if they are: 

  • Not intended to influence or reward improper performance. 

  • Declared and approved in line with the company’s procedures. 

  • In compliance with local laws and cultural norms. 

Extravagant or frequent gifts must be refused. 

6. Responsibilities 

All individuals covered by this policy must: 

  • Act honestly, ethically, and with integrity. 

  • Avoid any activity that could be perceived as corrupt. 

  • Report any suspected bribery or corruption immediately. 

Managers are responsible for ensuring their teams understand and comply with this policy. 

7. Reporting Concerns 

Concerns or suspicions should be reported to the Compliance Officer or via [Company’s Whistleblowing Channel, if available]. Reports will be treated confidentially and without fear of retaliation. 

8. Training and Communication 

All relevant individuals will receive training on this policy and the Bribery Act 2010. This policy will be communicated to all business partners and suppliers. 

9. Breaches of this Policy 

Breaches will be treated seriously and may lead to disciplinary action, including dismissal. Where appropriate, the company may involve law enforcement. 

10. Monitoring and Review 

This policy will be reviewed annually and updated as necessary to ensure it remains effective and in line with legal and regulatory developments. 

 

Last Updated: 25 May 2025