The Upgrade Authority Ltd (TUA)
The Upgrade Authority is committed to conducting business with integrity, fairness, and transparency. We have a zero-tolerance approach to bribery and corruption across all of our operations.
This policy sets out our responsibilities, as well as the responsibilities of those working with or on behalf of us, in upholding our position on anti-bribery and corruption.
Our Commitment
- We strictly prohibit the offering, giving, solicitation, or acceptance of any bribe, whether cash, gifts, hospitality, or services, intended to improperly influence a business outcome.
- We comply fully with the UK Bribery Act 2010 and all applicable anti-corruption laws in the regions where we operate.
- We will never tolerate “facilitation payments” or kickbacks, regardless of size or frequency.
- We promote a culture of honesty, transparency, and accountability across the group.
Scope
This policy applies to:
- All directors, employees, and contractors of TUA.
- Agents, consultants, suppliers, landlords, and partners acting on our behalf.
- Any third parties connected with our business operations.
Practical Guidelines
- Gifts & Hospitality: Reasonable and proportionate hospitality (e.g. business meals, branded items of modest value) is permitted if it is transparent, infrequent, and not intended to influence decision-making. Anything that could create a conflict of interest must be declared.
- Third Parties: We conduct due diligence on partners, suppliers, and contractors to ensure they share our zero-tolerance stance.
- Donations & Sponsorships: Charitable donations are only made in good faith and never to secure an improper business advantage. Political donations are strictly prohibited.
- Conflict of Interest: Any personal or financial interest that could interfere with business judgement must be disclosed to management immediately.
Responsibilities
- Board & Management: Ensure systems and controls are in place to detect and prevent bribery.
- Employees & Contractors: Must not engage in any form of bribery and are required to report suspicious activity.
- Partners & Suppliers: Must comply with this policy as a condition of doing business with TUA.
Reporting & Enforcement
- Concerns or suspected breaches should be reported to management or via a confidential whistleblowing channel.
- All reports will be investigated fairly and without retaliation.
- Breaches of this policy may result in disciplinary action, termination of contracts, and referral to law enforcement where applicable.
Date: April 2025