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Anti‑Bribery & Corruption (ABC) Policy

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Last updated: 2 November 2025
Company: InteliATE Ltd (Company No. 15514345)
Registered office: London, United Kingdom
Contact: contact@InteliATE.com (subject: Compliance)

1) Statement & Scope

InteliATE has zero tolerance for bribery and corruption. This Policy applies to all InteliATE people (employees, officers, directors), contractors, resellers/agents, and any third party acting for or on our behalf, anywhere in the world.

We comply with the UK Bribery Act 2010 (including the Section 7 “failure to prevent” offence and the MoJ’s six‑principle framework) and relevant local laws (e.g., US FCPA) where we operate or sell. GOV.UK+1

2) What’s prohibited

  • Bribery/kickbacks: Offering, giving, requesting, or receiving anything of value to influence a person’s actions or secure an improper advantage—public or private sector.

  • Facilitation payments: Banned. “Grease” payments are illegal under UK law; do not make them (exception only for immediate threat to life/safety—report immediately). GOV.UK

  • Cash or cash equivalents: Never permitted (cash, gift cards, vouchers, crypto).

  • Improper gifts/hospitality/travel: Anything intended or likely to influence a decision.

  • Political contributions: None on InteliATE’s behalf.

  • Charitable donations & sponsorships: Allowed only with pre‑approval and due diligence; never to influence a decision.

  • Hiring or internships: Must not be offered to influence a decision (including relatives of officials).

3) Government interactions (stricter rules)

  • Gifts/hospitality to public officials: Prohibited unless prior written approval from Compliance and demonstrably legitimate, modest, and lawful. Default rule: £0.

  • Permissible business courtesy (rare): Must be (i) clearly lawful, (ii) modest, (iii) transparently recorded, and (iv) pre‑approved.

4) Gifts, Hospitality & Expenses (commercial counterparties)

  • Never if intended to influence or appears excessive/inappropriate.

  • Thresholds:

    • Gifts: permitted up to £50 per person with disclosure; £50–£150 requires pre‑approval; >£150 prohibited.

    • Hospitality/Meals: reasonable, occasional; over £150 per person requires pre‑approval.

  • Always prohibited: cash/cash‑equivalents; “quid‑pro‑quo” offers; adult entertainment.

  • Register: All gifts/hospitality (given or received) must be logged in the ABC Register within 7 days.

(Adjust amounts if you prefer; the structure and controls should remain.)

5) Third parties (resellers, agents, partners, consultants)

  • Risk‑based due diligence before engagement; refresh periodically. Screen ownership, reputation, sanctions, and government ties; document red flags and mitigations.

  • Written contract with ABC clauses: compliance, audit/termination rights, accurate records, no sub‑agents without approval.

  • Monitoring: Validate invoices against deliverables; no off‑book payments or “success fees” without specific approval.

6) Books, Records & Controls

  • Keep complete, accurate, timely records for payments, expenses, gifts, hospitality, donations, sponsorships, and third‑party fees.

  • No off‑book accounts or falsified descriptions.

  • Maintain the ABC Register and supporting evidence for 6 years (or longer where legally required).

7) Conflicts of Interest

Disclose any personal, financial, or family interest that could influence your work (including with suppliers, partners, or customers). Do not participate in related decisions without clearance.

8) Training & Certification

  • Mandatory onboarding ABC training for all employees; annual refresh for higher‑risk roles (sales, channel, procurement, public‑sector engagement).

  • Third‑party representatives receive appropriate ABC communication and contractual obligations.

9) Speak‑Up & Non‑Retaliation

Report concerns immediately to contact@inteliate.com (subject: Compliance) or your manager. InteliATE prohibits retaliation against anyone who reports in good faith. Concerns are investigated promptly and fairly; substantiated violations lead to disciplinary action (up to termination) and reporting to authorities where required.

10) Risk Assessment, Monitoring & Review

We maintain proportionate procedures consistent with MoJ guidance: Proportionate procedures; Top‑level commitment; Risk assessment; Due diligence; Communication/training; Monitoring/review. We reassess risks at least annually and when entering new markets, using intermediaries, or bidding in public sector opportunities. GOV.UK

11) Roles & Responsibilities

  • Board/CEO: set tone, approve policy, oversee effectiveness.

  • Compliance Lead (policy owner): maintains this policy, keeps the ABC Register, approves higher‑risk gifts/hospitality/donations, and third‑party due diligence.

  • Managers: ensure team compliance and completion of training.

  • Everyone: read, understand, and follow this policy; complete training; raise concerns.

12) Enforcement

Breaches may result in disciplinary action (up to dismissal), contract termination, recovery of losses, and referral to law enforcement/regulators. InteliATE will cooperate with authorities.

13) Questions

Email contact@InteliATE.com (subject: Compliance).

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