This Anti-Bribery and Anti-Corruption Policy implements OSCABE LTD's commitments under the UK Bribery Act 2010 and equivalent laws applicable to our cross-border operations.
1. Zero tolerance
OSCABE conducts business honestly and ethically. We have a zero-tolerance position on bribery and corruption - whether public or private, direct or indirect, paid or received.
2. What is bribery?
A bribe is the offering, promising, giving, accepting or soliciting of any financial or other advantage to induce or reward improper performance of a function. It does not need to involve cash and it does not need to succeed.
3. Specific prohibitions
OSCABE staff, Engineers and Clients using the Platform must not:
- Offer or accept a bribe (including kickbacks for placements).
- Offer or accept facilitation payments (small payments to expedite routine services). The UK Bribery Act treats these as bribes.
- Offer gifts or hospitality of a value or frequency designed to influence a business decision.
- Use Platform features (messaging, file upload, AI chat) to communicate offers of bribery.
- Make political donations in OSCABE's name.
4. Gifts and hospitality
Modest, occasional, transparent business hospitality is permitted (for example, a working lunch). Any gift or hospitality with a value of more than £100 must be pre-approved by the CEO and logged in the Gifts Register.
5. Third-party due diligence
Before engaging a new sub-processor or major service provider we assess corruption risk and ensure the contract incorporates anti-bribery undertakings.
6. Training
All staff complete an anti-bribery training module annually. Senior staff with payment authority receive enhanced training.
7. Reporting
If you become aware of, or suspect, bribery in connection with OSCABE, report it immediately to info@oscabe.com with the subject "Whistleblower - Bribery". UK whistleblowers are protected under the Public Interest Disclosure Act 1998. We will investigate impartially and we will not retaliate.
8. Sanctions for breach
Breach of this policy may result in:
- Immediate termination of an OSCABE contract or account.
- Reporting to UK or local law-enforcement authorities.
- Civil claims for recovery of losses.
9. Review
This policy is reviewed annually by the CEO and updated to reflect changes in law and our risk profile.