Anti-Bribery & Corruption Policy

Policy Statement

World of Textiles UK LTD is committed to conducting business honestly and ethically. We have a zero-tolerance approach to bribery and corruption in any form. We will act professionally, fairly, and with integrity in all business relationships and transactions wherever we operate.

This policy applies to all forms of bribery, whether direct, indirect, public, or private. It covers bribes offered, promised, given, requested, agreed, received, or accepted, including kickbacks, facilitation payments, and other corrupt practices.

Purpose and Scope

This policy applies to:

• All employees (permanent, temporary, part-time, and full-time)
• Officers and directors
• Contractors and consultants
• Agency workers
• Agents acting on our behalf
• Joint venture partners and business associates
• Anyone else performing services for or on behalf of the organization

It applies worldwide, wherever we do business, and covers interactions with both public officials and private sector individuals and organizations.

Legal Framework

We comply with all applicable anti-bribery and corruption legislation, including:

• Bribery Act 2010 (UK) - criminalizes giving, promising, or offering a bribe, and requesting, agreeing to receive, or accepting a bribe
• Foreign Corrupt Practices Act 1977 (US FCPA) - where applicable
• UK Proceeds of Crime Act 2002
• UK Fraud Act 2006
• Local anti-corruption laws in all jurisdictions where we operate

Under the Bribery Act 2010, individuals found guilty of bribery can face up to 10 years’ imprisonment and unlimited fines. Organizations can face unlimited fines and reputational damage.

What is Bribery?

Definition

Bribery is offering, promising, giving, requesting, or accepting any financial or other advantage as an inducement or reward for improper performance of a relevant function or activity.

Examples of Bribery

Bribery may include:

• Cash payments or cash equivalents (gift cards, vouchers, etc.)
• Excessive or inappropriate gifts or hospitality
• Kickbacks or commission payments
• Preferential treatment or favors
• Political or charitable contributions used improperly
• Employment opportunities or internships offered as inducements
• Business opportunities given for improper purposes
• Use of third parties to channel payments
• Loans or guarantees at preferential rates
• Travel, accommodation, or entertainment expenses used improperly

Public vs Private Sector Bribery

Public sector bribery involves bribing foreign public officials, government employees, or officials of public international organizations.

Private sector bribery involves bribing individuals in commercial organizations to gain a business advantage.

Both are strictly prohibited.

Prohibited Activities

We prohibit:

Direct Bribes

Offering, giving, requesting, or receiving bribes directly.

Indirect Bribes

Using third parties (agents, consultants, intermediaries) to offer or receive bribes on our behalf.

Facilitation Payments

Small payments or “grease payments” made to secure or expedite routine government actions (e.g., processing visas, providing utilities, loading cargo). Even if commonplace in certain countries, facilitation payments are prohibited.

Kickbacks

Payments or benefits given in return for business favors or advantages, including receiving a portion of funds from a transaction as a reward for favorable treatment.

Secret Commissions

Undisclosed payments to agents or intermediaries who are supposed to act impartially.

Political Contributions for Improper Purposes

Making political contributions with the expectation of receiving business advantages in return.

Charitable Donations for Improper Purposes

Making charitable donations as a quid pro quo for business favors or to conceal bribes.

Gifts and Hospitality

Reasonable and proportionate business hospitality is an accepted part of business relationships. However, it must not be used to improperly influence business decisions.

Acceptable Gifts and Hospitality

Gifts and hospitality may be accepted or offered only if they:

• Are reasonable and proportionate in value (generally under £50/$75 per person)
• Are infrequent and not part of a pattern
• Are given openly and transparently
• Are properly documented and declared
• Do not create an obligation or expectation
• Comply with the recipient organization’s policies
• Are legal in the relevant jurisdiction
• Would not embarrass the company if publicly disclosed
• Are not cash or cash equivalents
• Are culturally appropriate and given/received in good faith

Unacceptable Gifts and Hospitality

Gifts and hospitality must NOT be:

• Excessive or lavish in nature
• Given or received during tender or negotiation processes
• Cash or cash equivalents (gift cards, vouchers, etc.)
• Intended to influence a business decision improperly
• Offered to or accepted from public officials without approval
• Secret or undisclosed
• Prohibited by the other party’s organization
• Illegal in the jurisdiction

Declaration Requirements

All gifts and hospitality over £25 ($40) in value must be declared using our gifts and hospitality register. This applies whether you give or receive.

For public officials, any gift or hospitality regardless of value must be pre-approved by senior management.

Third Parties and Business Partners

We recognize that corruption risks can arise through relationships with third parties who act on our behalf.

Due Diligence

Before engaging agents, consultants, intermediaries, or joint venture partners, we will:

• Conduct appropriate due diligence based on risk assessment
• Evaluate business reputation and integrity
• Understand ownership structure and relationships
• Assess previous involvement in corruption allegations
• Review their anti-bribery policies and procedures
• Obtain references and conduct background checks
• Assess the business rationale for the relationship

Contractual Protections

Contracts with third parties will include:

• Anti-bribery and anti-corruption clauses
• Right to audit and inspect records
• Obligation to comply with anti-bribery laws
• Representations and warranties regarding compliance
• Right to terminate for non-compliance
• Obligation to report suspected violations

Red Flags

We will be alert to warning signs including:

• Requests for unusual payment arrangements (cash, offshore accounts, third countries)
• Lack of transparency about owners or principals
• Reluctance to provide due diligence information
• Poor business reputation or rumors of corruption
• Excessive commission or fee structures
• Political connections combined with lack of relevant expertise
• Insistence on confidentiality
• Last-minute changes to agents or payment recipients

Responsibilities

Senior Management

Senior management will:

• Lead by example and promote ethical culture
• Ensure adequate anti-bribery resources and controls
• Approve high-risk relationships and transactions
• Monitor compliance and address issues
• Support employees who report concerns
• Ensure appropriate training is provided

Line Managers

Managers must:

• Implement this policy within their areas
• Ensure team members understand requirements
• Monitor gifts and hospitality within their teams
• Conduct due diligence on third parties
• Approve declarations within their authority
• Escalate concerns promptly
• Support the reporting of suspected violations

All Employees

Employees must:

• Understand and comply with this policy
• Never offer, promise, give, request, or accept bribes
• Declare gifts and hospitality appropriately
• Conduct themselves ethically in all dealings
• Complete required anti-bribery training
• Report suspicions or concerns immediately
• Cooperate with investigations

Reporting Concerns and Whistleblowing

How to Report

If you suspect bribery or corruption:

1. Report to your manager if you feel comfortable doing so
2. Contact senior management directly
3. Use the confidential email: info@worldoftextiles.com
4. Use the whistleblowing procedure for serious concerns
5. Contact external authorities if appropriate (Serious Fraud Office)

Protection from Retaliation

We will not tolerate retaliation against anyone who:

• Raises genuine concerns about bribery or corruption
• Refuses to engage in bribery even if it means losing business
• Reports suspected violations in good faith
• Participates in investigations

Retaliation against whistleblowers will be treated as serious misconduct and may result in dismissal.

Confidentiality

Reports will be handled confidentially. Your identity will be protected wherever possible, though we may need to disclose it during investigations or legal proceedings.

Investigation and Enforcement

Investigation Process

Allegations of bribery will be:

• Taken seriously and investigated promptly
• Handled confidentially and professionally
• Conducted by appropriate personnel
• Documented thoroughly
• Reported to authorities where required
• Addressed through appropriate disciplinary action

Disciplinary Action

Violations of this policy will result in disciplinary action up to and including:

• Written warnings
• Suspension
• Dismissal for gross misconduct
• Referral to law enforcement authorities
• Civil or criminal prosecution

Bribery is a criminal offense that can lead to imprisonment and unlimited fines for individuals and organizations.

Training and Awareness

We provide:

• Induction training on anti-bribery for all new starters
• Regular refresher training for all employees
• Enhanced training for roles with higher corruption risks
• Scenario-based training on recognizing and handling bribery situations
• Updates when policies or regulations change
• Resources including guidance documents and FAQs

Training attendance is mandatory and records are maintained.

Record Keeping

We maintain accurate financial and business records, including:

• Detailed records of all gifts and hospitality given or received
• Due diligence documentation for third parties
• Contracts with anti-bribery provisions
• Training records
• Investigation documentation
• Declaration forms and approvals

Records must:

• Be accurate, complete, and truthful
• Be maintained for at least 6 years
• Be available for inspection and audit
• Not conceal or disguise true purposes of payments

False accounting is a criminal offense under the Fraud Act 2006.

Monitoring, Review, and Continuous Improvement

We will:

• Conduct regular internal audits of compliance
• Monitor gifts and hospitality registers
• Review third-party relationships periodically
• Assess emerging corruption risks
• Track training completion rates
• Benchmark against best practices
• Update policies based on lessons learned

This policy will be reviewed at least annually or following:

• Significant incidents or allegations
• Changes in anti-bribery legislation
• Organizational changes
• Entry into higher-risk markets
• Recommendations from audits or investigations

Country-Specific Considerations

When operating in different jurisdictions:

• Understand local laws and comply with the stricter of UK or local requirements
• Seek legal advice in high-risk jurisdictions
• Adapt procedures to local contexts while maintaining standards
• Train employees on specific local risks
• Document country-specific procedures where necessary

Dealing with Public Officials

Particular care must be taken when dealing with public officials, including:

• Government employees and officials
• Employees of state-owned enterprises
• Political party officials
• Candidates for political office
• Officials of public international organizations (UN, World Bank, etc.)

Any gifts, hospitality, or payments to public officials require pre-approval from senior management and must be:

• For legitimate purposes only
• Proportionate and reasonable
• Transparent and properly documented
• In compliance with local laws
• Not intended to improperly influence decisions

Consequences of Non-Compliance

For Individuals

• Criminal prosecution (up to 10 years’ imprisonment under Bribery Act 2010)
• Unlimited fines
• Director disqualification
• Professional sanctions
• Reputational damage
• Dismissal

For the Organization

• Unlimited fines
• Debarment from public contracts
• Loss of licenses or permits
• Reputational damage
• Shareholder and stakeholder sanctions
• Civil liability and claims

Contact and Support

For guidance or to report concerns:

• Email: info@worldoftextiles.com
• Telephone: +44 1234 567 890
• Confidential Hotline: [To be established]
• Write to: Senior Management Team, World of Textiles UK LTD

External resources:

• Serious Fraud Office (SFO): Report fraud and corruption
• Action Fraud: 0300 123 2040
• Transparency International UK: Anti-corruption resources
• Institute of Business Ethics: Guidance and support

Certification

All employees in relevant roles will be required to certify annually that they:

• Have read and understood this policy
• Have complied with its requirements
• Are not aware of any violations
• Have declared all relevant gifts and hospitality

Commitment

We are committed to:

• Conducting business ethically and with integrity
• Preventing bribery and corruption in all forms
• Promoting a culture of compliance
• Supporting employees who raise concerns
• Continuous improvement in anti-bribery practices

Approved by: Board of Directors Policy Owner: Chief Compliance Officer / Senior Management Next Review Date: December 2026 Version: 1.0