ANTI-BRIBERY & CORRUPTION POLICY¶
Ref: HPOL09 | Version: 2.0 | Date: 17/02/2026 | Classification: CRGI Information
| Version | Date | Author | Changes |
|---|---|---|---|
| 1.0 | 01/04/2025 | Sean Ashton | Initial issue (POL_14) |
| 2.0 | 17/02/2026 | Sean Ashton | Consolidated to policy-level commitments — manuals as core reference |
Policy Statement¶
CRGI Solutions has zero tolerance for bribery and corruption. We shall conduct all business dealings ethically, transparently, and in compliance with the Bribery Act 2010. All staff are required to act with integrity and report any suspected bribery or corrupt practices.
Key Requirements¶
- Staff shall not offer, promise, give, request, or accept any bribe — whether financial or otherwise — to or from any person.
- Facilitation payments are prohibited regardless of local custom or practice.
- Gifts and hospitality shall only be accepted or offered if they are reasonable, proportionate, transparent, and recorded.
- Due diligence shall be conducted on suppliers, subcontractors, and agents before engagement to assess bribery risk.
- Staff shall report any suspected bribery or corruption to the Operations Manager or CEO immediately.
- A risk-based approach shall be applied to identify and mitigate bribery risks in business relationships and transactions.
- Records of gifts, hospitality, and due diligence checks shall be maintained.
- Breaches of this policy shall be treated as gross misconduct and may result in immediate termination of engagement and referral to law enforcement.
Applicable Legislation¶
- Bribery Act 2010
- Proceeds of Crime Act 2002
- Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
Related Documents¶
| Reference | Document |
|---|---|
| HPOL07 | Code of Conduct |
| HPOL13 | Modern Slavery Statement |
| HPOL14 | Ethical Purchasing Policy |
| HPROC08 | Supplier Assessment Procedure |
| Role | Name | Signature | Date |
|---|---|---|---|
| Owner | Sean Ashton, Operations, HSQE & Technical Manager | S.Ashton | 17/02/2026 |
| Approved | Dragos Ciordas, Chief Executive Officer | D.Ciordas | 17/02/2026 |
Approved by: Dragos Ciordas, CEO — 17 February 2026
Next Review: February 2027
Distribution: All Staff