Anti-Bribery & Corruption Policy

4.4 Improper Influence

Influencing a decision-maker outside of normal, transparent procedures.

4.5 Kickback

A payment returned as a reward for awarding a contract or favour.

4.6 High-Risk Third Party

Any external individual or organisation acting on the Company’s behalf, particularly in procurement, negotiation, or international dealings.

5. Responsibilities (Expanded)

5.1 Managing Director / Senior Leadership

• Demonstrate clear top-level commitment.
• Ensure robust controls, training, due diligence, and reporting mechanisms.
• Approve and review the policy annually.
• Support investigations into suspected breaches.

5.2 Managers

• Promote ethical behaviour and enforce compliance.
• Identify and report risks and red flags.
• Ensure staff receive training and guidance.
• Maintain accurate records within their departments.

5.3 Employees

Employees must not:

• Engage in bribery or corruption.
• Ignore suspicious behaviour or red flags.
• Accept cash or items of value that could influence decisions.
• Conceal financial irregularities.
• Destroy or falsify records.

Employees must:

• Declare conflicts of interest.
• Report suspected wrongdoing immediately.
• Maintain integrity and professionalism at all times.
• Complete mandatory anti-bribery training.

5.4 Subcontractors & Suppliers

• Must comply as a condition of working with Vogal Group.
• Must not offer inducements, gifts, or incentives to employees.
• Must complete due diligence checks when requested.

6. Prohibited Behaviours (Expanded)

The following are strictly prohibited:

6.1 Bribes (Offering/Giving/Receiving)

Any attempt to influence:

• Contract awards
• Planning decisions
• Tender evaluations
• Procurement selections
• Supplier negotiations
• Inspections or audits

6.2 Facilitation Payments

Examples include:

• Payments to speed up licence issuance
• Payments to customs officers
• Payments to secure utility connections

6.3 Kickbacks

Commission payments or benefits given in return for favouring a business.

6.4 Improper Gifts & Hospitality

Anything excessive, lavish, unusual, or linked to an expected outcome is prohibited.

6.5 Political Contributions

The Company will not make payments to political parties, individuals, or campaigns.

6.6 Charitable Donations

Donations must:

• Be transparent
• Be approved by senior management
• Never be used as a route for bribery

6.7 Employment Bribery

Offering jobs, internships, or work placements in return for business advantage is forbidden.

7. Gifts, Hospitality & Corporate Courtesy (Expanded)

Vogal Group permits reasonable, proportionate hospitality where:

• It supports legitimate business relationships
• It is not excessive or intended to influence decisions
• It does not create reputational or legal risk

Examples allowed with prior approval:

• Working lunches of modest value
• Occasional tickets to events where staff attend
• Branded promotional items of low value

Examples never allowed:

• Cash or cash equivalents
• Holiday trips unrelated to business
• Lavish meals, expensive venues, or VIP experiences
• Gifts received during active tendering processes

A Gifts & Hospitality Register must be maintained and reviewed quarterly.

8. Conflicts of Interest (Expanded)

Employees must declare if they:

• Have relatives working for clients or suppliers
• Are offered secondary employment with a supplier
• Receive personal benefits from a competitor
• Have financial interest in a bidding company

Undeclared conflicts may result in disciplinary action.

9. High-Risk Situations & Red Flags

Employees must be vigilant for red flags including:

• Requests for cash payments
• Requests for payment to offshore accounts
• Intermediaries offering to “open doors”
• Unwillingness to provide documented costs
• Vague service descriptions
• Refusal to sign contracts or use official channels
• Excessive commissions or “marketing fees”
• Pressure for quick decisions
• Unusual gifts or travel offers

Any red flag must be reported immediately.

10. Due Diligence (Expanded)

Before engaging third parties, Vogal Group will:

• Conduct background checks
• Verify ownership structure
• Review sanctions lists
• Assess bribery risk level (high/medium/low)
• Request and review relevant policies and certifications
• Obtain declarations of compliance
• Include contractual anti-bribery clauses

Higher-risk relationships require enhanced due diligence.

11. Financial Controls

To prevent fraud, bribery, or improper influence:

• All payments must be approved through authorised channels.
• Cash handling is restricted.
• Dual authorisation is required for certain transactions.
• Accurate and complete financial records must be kept.
• No off-book or anonymous accounts are permitted.

False accounting is a criminal offence.

12. Reporting & Whistleblowing (Expanded)

Employees must report:

• Suspected bribes
• Requests for improper payments
• Suspicious supplier behaviour
• Irregular financial activity
• Evidence of falsified records
• Any breach of this policy

Reports can be made to:

• Manager
• Health & Safety / Compliance Manager
• Managing Director

Employees can report anonymously where possible and will be protected under the Company’s Whistleblowing Policy.

Retaliation against whistleblowers is strictly prohibited.

13. Investigation Process

All reports will be:

• Logged and acknowledged
• Investigated promptly and confidentially
• Reviewed by senior management
• Documented with evidence
• Subject to corrective actions and disciplinary measures
• Reported to authorities when required

Possible outcomes include:

• Training or coaching
• Disciplinary action
• Contract termination
• Police referral
• Civil recovery

14. Training & Awareness

• All employees must complete anti-bribery training.
• Training will be renewed annually or when legislation changes.
• Records of training will be maintained for audit purposes.
• Additional training is provided for procurement and commercial teams.

15. Monitoring, Audit & Review

Vogal Group will:

• Conduct periodic audits of financial and procurement processes
• Perform risk assessments annually
• Review the policy each year
• Monitor third-party compliance
• Implement corrective actions where required

16. Associated Documents

• Whistleblowing Policy
• Gifts & Hospitality Register
• Modern Slavery & Ethical Trading Policy

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