PHC Digital Ltd Anti-Bribery and Anti-Corruption Policy

Policy key definitions

• “I”, “our”, “us”, or “we” refer to PHC Digital Ltd, 7 The Close, Norwich, Norfolk NR1 4DJ, UK.
• “Bribery” refers to offering, giving, requesting, or receiving anything of value as an inducement or reward for improper performance of a relevant function or activity.
• “Corruption” refers to the abuse of entrusted power for private gain.
• “Associated Persons” refers to employees, contractors, consultants, agents, suppliers, or any other persons performing services for or on behalf of PHC Digital Ltd.

Overview

PHC Digital Ltd is committed to conducting business in an honest, ethical, and transparent manner. We take a zero-tolerance approach to bribery and corruption and are committed to complying with all applicable laws, including the UK Bribery Act 2010.

This Policy applies to all employees, directors, officers, contractors, temporary workers, and anyone acting on behalf of PHC Digital Ltd, regardless of location.

Our commitment

We commit to:

  • Prohibit bribery and corruption in all forms.
  • Act professionally, fairly, and with integrity in all business dealings and relationships.
  • Implement effective systems and controls to prevent bribery and corruption.
  • Ensure all Associated Persons understand and comply with this Policy.

Prohibited conduct

Under no circumstances may any Associated Person:

  • Offer, promise, give, request, or accept a bribe.
  • Make facilitation payments of any kind (payments made to secure or expedite routine government actions).
  • Offer gifts, hospitality, or expenses that could improperly influence, or be perceived to influence, a business decision.
  • Engage in any form of corrupt behaviour whether directly or indirectly through third parties.

Gifts, hospitality, and expenses

Reasonable and proportionate hospitality or promotional expenditure is permitted where it is:

  • Legitimate and transparent.
  • Not intended to improperly influence a decision.
  • Infrequent, modest in value, and appropriate to the business context.
  • Accurately recorded in company records.

Cash gifts or cash equivalents are strictly prohibited.

Responsibilities and governance

The Managing Director, Pete Henshall, has overall responsibility for ensuring compliance with this Policy and for overseeing its implementation and effectiveness.

All employees and Associated Persons are responsible for:

  • Reading, understanding, and complying with this Policy.
  • Avoiding any activity that could lead to, or suggest, a breach of this Policy.
  • Reporting concerns or suspected breaches immediately.

Risk assessment and due diligence

PHC Digital Ltd will:

  • Assess bribery and corruption risks relevant to its business activities and supply chains.
  • Conduct proportionate due diligence on third parties and suppliers where appropriate.
  • Review business relationships where risks are identified and take corrective action where necessary.

Reporting concerns

Any concerns or suspicions of bribery or corruption must be reported promptly. Reports may be made in confidence to:

Email: contact@phc-digital.com
Tel: +44 01953 529027

PHC Digital Ltd will investigate all reports fairly and confidentially. No individual will suffer detrimental treatment for raising a genuine concern, even if it later proves to be unfounded.

Breaches of this Policy

Any breach of this Policy may result in disciplinary action, up to and including dismissal, termination of contracts, and/or reporting to relevant authorities.

Review and monitoring

This Policy will be reviewed at least annually and updated as necessary to ensure ongoing compliance with legal requirements and best practice.

Approval

This Anti-Bribery and Anti-Corruption Policy was approved by the Board of PHC Digital Ltd.