Bribery and Corruption Policy

This policy applies to directors, employees, contractors and anyone acting for The Upgrade Authority. It reflects the standards expected under the Bribery Act 2010.

Core Rule

Do not offer, promise, give, request or accept a financial or other advantage intended to influence a decision improperly. Facilitation payments and kickbacks are not permitted. The rule applies whether the advantage is offered directly or through another person.

Gifts, Hospitality and Conflicts

A modest and legitimate business gift or hospitality may be acceptable where it is transparent, infrequent and cannot reasonably be seen as influencing a decision. Anything unusual, valuable or connected to a live decision must be declared to a director before it is accepted. Personal or financial interests that could affect business judgement must also be declared.

People Acting for the Group

A supplier, agent, consultant or other person acting for the group must not use bribery to obtain work, licences, information or a commercial advantage. Checks and written terms should be proportionate to the role, country, transaction value and other identified risks.

Raising a Concern

Report a suspected bribe, undeclared conflict or improper request promptly to a director. You can also use the contact page. A concern raised honestly should be assessed fairly and the information shared only with people who need it to respond.

Response and Review

A substantiated breach may lead to disciplinary action, the end of a commercial relationship or referral to an appropriate authority. The response will depend on the evidence, the contract and applicable law.

Last updated: 27 August 2026.