Anti-Bribery and Corruption Policy

What Does This Policy Cover?

This Anti-Bribery and Corruption policy exists to set out the responsibilities of CapExpand Ltd and its employees and third parties, to observe and uphold our zero-tolerance position on bribery and corruption. This document acts as a source of information and guidance and helps with recognising and dealing with bribery and corruption issues, as well as understanding your responsibilities.

Who Is Covered by the Policy?

This anti-bribery policy applies to all employees (whether temporary, fixed term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Board, and/or Committee members at any level.

Definition of Bribery

The Bribery Act 2010 defines bribery as accepting or receiving a financial or other advantage in connection with the “improper performance” of a position of trust, or a function that is expected to be performed impartially or in good faith.

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage in order to induce or influence an action or decision. A bribe refers to any inducement, reward, or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage.

Bribery does not mean it just involves cash, or a payment exchanging hands and can take many forms such as a gift, lavish treatment during a business trip or tickets to an event.

Some examples of bribery in the commercial sector include:

• Bribery to secure or keep a contract
• Bribery to secure an order
• Bribery to gain any advantage over a competitor
• Bribery of a local, national, or foreign official to secure a contract
• Bribery to turn a blind eye to a health and safety issue or poor performance
• Bribery to falsify an inspection report or obtain a certificate

CapExpand Ltd therefore has a zero-tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all its business dealings and relationships wherever it operates and implementing and enforcing effective systems to counter bribery.

All employees including the Director are expected to adhere to the principles set out in this policy. An individual found guilty of an offence may be liable on summary conviction to imprisonment, or to a fine, or to both; or on conviction on indictment, to imprisonment for a term not exceeding 10 years, or to a fine, or to both.

To Comply with the Legislation, We:

• Have adequate procedures in place to prevent bribery
• Have proportionate controls to ensure that procedures are adequate to minimise the risk
• Ensure that any action taken is proportionate to the risk within the business
• Set the tone from the top - demonstrating that all staff, agents, and the key people with whom we do business with and for understand that we will not tolerate bribery
• Perform due diligence - know exactly whom we are dealing with and undertake checks before engaging others to represent us in business dealings
• Communicate policies and procedures to all employees to enhance awareness and advise what is acceptable
• Monitor and review the risks faced, particularly if entering a new market

Gifts and Hospitality

CapExpand Ltd can accept normal and appropriate gestures of hospitality and goodwill (whether given to or received from third parties) so long as the giving or receiving of gifts meets the following requirements:

• It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits
• It is not made with the suggestion that a return favour is expected
• It follows the UK Bribery Act
• It is given in the name of the company, not in an individual's name
• It does not include cash or a cash equivalent (e.g., a voucher or gift certificate)
• It is appropriate for the circumstances (e.g., giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion)
• It is of an appropriate type and value and given at an appropriate time, considering the reason for the gift

From time to time, external stakeholders and suppliers may offer a gift to an employee. As good practice, gifts given and received should always be disclosed to the Director. If the value is £50 or more it requires authorisation.

If a gift is offered and then refused because of its value, this must be reported to the Director.

Hospitality

Occasionally, external stakeholders may invite an employee to a hospitality event such as a meal, football match, business party, horseracing, or wine-tasting. All such invitations must be reported to the Director for authorisation prior to accepting the offer to attend the event.

What Is Not Acceptable?

• Accepting any financial or other reward from any person in return for providing a relevant function or activity, performed improperly
• Requesting a financial or other reward from any person in return for providing a relevant function or activity, performed improperly
• Offering any financial or other reward to any person in return for providing a relevant function or activity, performed improperly

Facilitation Payments and Kickbacks

CapExpand Ltd does not accept and will not make any form of facilitation payments of any nature. It is recognised that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. They are not commonly paid in the UK but may be common in some other jurisdictions.

CapExpand Ltd does not allow kickbacks to be made or accepted. Kickbacks are typically payments made in return for a business favour or advantage.

If you have been asked to make any payment on behalf of the company, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should request an invoice or a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Director.

Responsibilities of Staff

As an employee of CapExpand Ltd, it is your responsibility to ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.

All employees are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption and to report if they suspect an instance of bribery or corruption has occurred or may occur. If any employee breaches this policy, they may be subject to disciplinary action and could face dismissal for gross misconduct.

Expenses

The Director must authorise all expenses claims. All expenses will need to be verified by paper or digital receipts. Any item of expenditure that is not supported by a receipt or gives rise to concern that bribery may have taken place must be fully investigated at the earliest opportunity.

Charitable Contributions

CapExpand Ltd may make charitable donations, managed by the Director. CapExpand Ltd will ensure that all charitable donations made are legal and ethical under law and regulations and donations are not made to political parties or other organisations with the intention of gaining personal or business advantage or to facilitate and conceal acts of bribery.

How to Raise a Concern

If you suspect any occurrence of bribery or corrupt activities, you are encouraged to report these concerns at the earliest stages. CapExpand Ltd will provide guidance to employees on how to raise concerns confidentially.

Protection

If you refuse to accept or offer a bribe, CapExpand Ltd understands that employees may feel concerns about possible repercussions of reporting concerns relating to acts of bribery or corruption.

CapExpand Ltd will ensure the employee should not suffer any detrimental treatment (relating to dismissal, disciplinary action, unfavourable treatment) because they have reported a concern relating to potential act(s) of bribery or corruption. CapExpand Ltd will support any employee who raises these concerns in good faith, even if the investigation concludes there were no issues.

Training and Communication

CapExpand Ltd will provide training on this policy as part of the induction process for new staff. Each employee will receive annual training on how to adhere to this policy and will be requested to sign a declaration they acknowledge and will comply with this policy.

This zero-tolerance policy will be communicated to all suppliers, contractors, business partners, and all third parties at the commencement of the business relationship.

Record Keeping

CapExpand Ltd holds accurate financial records and has internal control processes in place, which require evidence of any payments made. This includes a written record of the amount and reason for hospitality or gifts accepted and given, which is subject to review.

Monitoring and Reviewing

The Director is responsible for reviewing and assessing the implementation of this policy on a regular basis. Any required changes or improvements should be implemented as soon as possible.

Date last reviewed: April 2026