Anti-Bribery and Corruption Policy

Policy Statement and Commitment

I, Dr Dave Wood, as the sole proprietor of Metanoeo, operate a zero-tolerance policy towards bribery and corruption. I am committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems to counter bribery.

I am bound by and committed to upholding the UK Bribery Act 2010. This policy applies to all business activities, including interactions with clients, trainees, suppliers, public officials, and subcontractors.

What is Bribery?

Bribery is defined as offering, promising, giving, requesting, receiving, or agreeing to receive a financial or other advantage in exchange for improper performance or improper influence.

This policy specifically prohibits:

• Bribing a Public Official: Offering anything of value to a foreign public official with the intent to obtain or retain business or an advantage.
• Receiving a Bribe: Accepting or agreeing to accept a financial or other advantage in return for improperly performing my coaching or training services.
• Undue Influence: Offering a client/trainee a personal advantage in exchange for securing their continued business or a referral.
  

Gifts, Hospitality, and Expenses

The offering or receipt of gifts and hospitality is a low-risk area for this business but must be handled transparently to avoid the appearance of undue influence. The following bullet points relate to the policy, gifts and permitted limits:

• Gifts Received: Modest, low-value promotional items (e.g., pens, notepads) are acceptable. Cash or cash equivalents are strictly prohibited. Any gift over £50 must be documented and declined or donated.
• Gifts Given: I may offer reasonable and proportionate promotional gifts (e.g., branded water bottle) to clients or trainees, provided they are not intended to influence a business decision.
• Hospitality: Accepting or offering reasonable and proportionate corporate hospitality (e.g., coffee/lunch during a training event) is permitted, provided the expenditure is legitimate, transparent, and intended to build relationships, not exert influence.
• Facilitation Payments: Strictly prohibited. These are small payments demanded by officials to speed up routine government actions (e.g., getting a visa).

Responsibilities and Reporting

As a sole trader, I am responsible for ensuring full compliance with this policy.

• Due Diligence: I will conduct appropriate due diligence on any third parties, partners, or subcontractors, ensuring their commitment to anti-bribery principles is consistent with my own.
• Whistle blowing/Reporting: If I suspect any instance of bribery or corruption related to my business, I will immediately take action to investigate and report the concern to the appropriate external authority (e.g., the Police or the Serious Fraud Office, if necessary).
• Contract Termination: Any breach of this policy by a subcontractor or supplier will lead to the immediate termination of the business relationship.
  

Review

This policy will be reviewed and updated annually to ensure it remains effective, compliant with the UK Bribery Act 2010, and appropriate for the current business operations.