Anti-Bribery and Corruption Policy

EB UNLOCKED LTD (trading as Unlocked Expertise) does not tolerate bribery or corruption in any form. We conduct our business honestly, fairly and openly, and we comply with the Bribery Act 2010 and all other applicable anti-corruption laws.

We work with businesses, mentors, programme partners and public bodies. Each of them needs to be able to trust that our decisions, and the work we win, rest on merit alone. This policy explains what we expect and what to do if something does not feel right.

This policy applies to everyone who works for us or on our behalf, including

• our directors and anyone we employ
• mentors, coaches, specialists and associates delivering services through Unlocked
• contractors, consultants, agents and delivery partners acting for us

It covers all of our activity, including commercial work, funded programmes and contracts with public-sector bodies.

Bribery means offering, promising, giving, requesting or accepting a financial or other advantage in order to influence someone to act improperly, or as a reward for having done so. The advantage does not have to be money. It can be a gift, hospitality, a favour, a job offer or anything else of value.

Corruption is the wider abuse of a position of trust for private gain. Under the Bribery Act 2010 it is an offence to bribe, to be bribed, to bribe a foreign public official, and for a company to fail to prevent bribery by people acting on its behalf.

Nobody covered by this policy may

• offer, promise or give a bribe, directly or through someone else
• ask for, agree to receive or accept a bribe
• make facilitation payments, which are small unofficial payments to speed up a routine process
• offer or accept kickbacks, secret commissions or undisclosed referral fees
• offer anything of value to a public official, or to anyone involved in a funding or procurement decision, in order to influence that decision
• disguise a payment or benefit, or record it inaccurately in our accounts

Modest, occasional gifts and hospitality can be a normal part of building working relationships. They are acceptable only when they are reasonable in value, given openly, not given in cash, and not intended or likely to influence a decision.

• Any gift or hospitality given or received with a value over £50 must be approved by a director and recorded in our gifts and hospitality register.
• We do not offer or accept gifts or hospitality of any value to or from anyone involved in a live procurement, tender evaluation or funding decision that concerns us.
• Mentors must not accept gifts, payments or other benefits from businesses they support beyond what is agreed through the platform, other than small tokens of thanks.

Much of our work is commissioned by public bodies, so we take particular care during procurement. When we bid for or deliver public contracts we

• follow the Procurement Act 2023 and the rules set by each contracting authority
• do not canvass or lobby officials or evaluators about a live procurement
• do not seek confidential information about other bidders or about an evaluation
• do not agree prices or bid content with competitors
• declare any actual or potential conflict of interest as soon as we become aware of it

Anyone covered by this policy must tell us about any personal, financial or family interest that could affect, or appear to affect, their judgement. Mentors must declare any conflict with a business before working with it, and we will not match a mentor with a business where a conflict cannot be managed. Declared conflicts are recorded and reviewed by a director.

We do not make political donations. Any charitable donation or sponsorship must be made openly to a legitimate organisation, approved by a director, recorded, and must never be used to influence a business or procurement decision.

We expect everyone who works with us to share our standards. This policy applies to every mentor on the platform alongside our mentor terms, and mentors who breach it may be removed from the platform.

Before engaging an associate, delivery partner or significant supplier we carry out proportionate checks, and our contracts allow us to end the relationship if this policy is breached.

We keep accurate and complete financial records. All payments, including payments to mentors and suppliers, are made through traceable channels and recorded with a clear business purpose. We never keep off-book accounts.

If you are offered a bribe, are asked to make one, or suspect that bribery or corruption is happening in connection with Unlocked, please tell us as soon as possible. Contact a director directly or email support@unlockedexpertise.com and mark your message confidential.

We will treat every report seriously and confidentially. Nobody will suffer any detriment for refusing to take part in bribery or for raising a genuine concern in good faith, even if it turns out to be mistaken. You can also report suspected bribery to the Serious Fraud Office.

A breach of this policy is treated as a serious matter. For mentors, associates and suppliers it may lead to removal from the platform or the end of their contract. Where appropriate we will report the matter to the relevant authorities and cooperate fully with any investigation, including informing any public body whose contract is affected.

The directors of EB UNLOCKED LTD are responsible for this policy and for making sure it is followed. Mentors and associates are made aware of it when they join, and it is shared with delivery partners on public contracts.

We review this policy at least once a year, and sooner if the law, our business or our contracts change. We will provide a signed confirmation of compliance with the Bribery Act 2010 to any contracting authority that asks for one.