Willix Limited - Anti-Bribery and Corruption Policy

Registered name: Willix Limited

Registered Company Location:14 Museum Place, Caerdydd, United Kingdom, CF10 3BH

Registered Company Number:16166712

Willix Limited Anti-Bribery and Corruption Policy

1. Introduction

Willix Limited is committed to conducting its business with integrity, transparency, and accountability. This Anti-Bribery and Corruption Policy outlines our zero-tolerance approach to bribery and corruption in any form, ensuring compliance with applicable laws and promoting ethical practices across our organization.

2. Scope

This policy applies to all employees, contractors, agents, and business partners of Willix Limited. It extends to all activities undertaken on behalf of the company, regardless of location.

3. Definitions

- Bribery: Offering, giving, receiving, or soliciting anything of value to influence a decision or gain an improper advantage.

- Corruption: Abuse of power for personal or organizational gain.

- Facilitation Payments: Small payments made to expedite routine government actions.

4. Prohibited Practices

Willix Limited strictly prohibits:

- Offering, promising, or giving bribes to secure a business advantage.

- Accepting bribes in any form, including gifts, cash, or favors.

- Engaging in corrupt practices, including extortion or embezzlement.

- Making or authorizing facilitation payments, except where there is a genuine threat to personal safety.

5. Gifts and Hospitality

While reasonable gifts and hospitality can foster business relationships, they must never:

- Influence or appear to influence business decisions.

- Be excessive, inappropriate, or in violation of this policy.

Employees must disclose all gifts or hospitality exceeding a defined monetary threshold to their manager or the compliance team.

6. Third-Party Relationships

Willix Limited expects all third parties acting on our behalf to adhere to our Anti-Bribery and Corruption Policy. This includes:

- Conducting due diligence before engaging with third parties.

- Ensuring clear contractual agreements that include anti-bribery clauses.

- Monitoring third-party activities for compliance with ethical standards.

7. Reporting and Whistleblowing

We encourage employees and stakeholders to report any suspected bribery, corruption, or unethical behavior. Reports can be made through:

- Whistleblowing Channels: Confidential reporting systems managed by the compliance team.

- Direct Communication: Reporting to managers or designated compliance officers.

Willix Limited guarantees protection from retaliation for individuals who report concerns in good faith.

8. Training and Awareness

To ensure understanding and compliance:

- All employees will receive training on anti-bribery and corruption policies.

- Regular updates and refresher courses will be provided.

- Communication materials will reinforce the importance of ethical practices.

9. Monitoring and Compliance

Willix Limited will:

- Regularly audit and review operations to identify and mitigate bribery risks.

- Investigate allegations promptly and thoroughly.

- Enforce disciplinary actions, up to and including termination, for violations of this policy.

10. Consequences of Non-Compliance

Violations of this policy may result in:

- Disciplinary action for employees, including dismissal.

- Termination of contracts with third parties.

- Legal action and penalties under applicable anti-bribery and corruption laws.

11. Policy Updates

This policy will be reviewed periodically and updated as necessary to reflect changes in laws, regulations, or company operations.

12. Contact Information

For questions or concerns regarding this policy, please contact:

- Email: [compliance@willixlimited.com](mailto:compliance@willixlimited.com)

- Phone: 01633 495178

- Address: Willix Limited, 123 Business Avenue, City, Country

By adhering to this policy, we collectively uphold the integrity and reputation of Willix Limited while fostering an ethical business environment.