Anti-Bribery & Anti-Corruption Policy

1. Statement

TRM Flex Limited has a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and to implementing and enforcing effective systems to counter bribery in line with the Bribery Act 2010.

2. Scope

This policy applies to:

• directors, officers and employees of TRM Flex Limited;
• self-employed contractors and agency staff acting for or on behalf of TRM Flex;
• suppliers, agents, advisers and any other person performing services for or on behalf of TRM Flex.

All such persons (“associated persons” for the purposes of section 7 of the Bribery Act 2010) are required to comply with this policy when performing services for us.

3. The law

The Bribery Act 2010 creates four key offences:

• Section 1 — offering, promising or giving a bribe (active bribery).
• Section 2 — requesting, agreeing to receive or accepting a bribe (passive bribery).
• Section 6 — bribery of a foreign public official.
• Section 7 — failure of a commercial organisation to prevent bribery by an associated person.

Individual offences carry penalties of up to 10 years' imprisonment and an unlimited fine. The corporate “failure to prevent” offence under section 7 carries an unlimited fine. The only defence under section 7 is that the organisation had “adequate procedures” in place to prevent bribery; this policy is part of those procedures.

4. What is prohibited

You must not, directly or indirectly:

• offer, promise, give, request, agree to receive or accept any financial or other advantage with the intent to induce or reward improper performance of a function or activity;
• make a facilitation payment of any size (these are illegal under UK law regardless of local custom);
• offer or accept gifts, hospitality or expenses that could improperly influence a business decision or create the appearance of doing so;
• make political donations on behalf of TRM Flex;
• make charitable donations on behalf of TRM Flex without prior written approval from a director.

5. Gifts and hospitality

Reasonable and proportionate gifts and hospitality given or received in the normal course of business are permitted, provided they:

• are not made with the intention of influencing a business decision;
• are not made to obtain or retain business or a business advantage;
• comply with the recipient's own gifts policy;
• are openly given, properly recorded and not in cash or cash equivalents;
• are reasonable in value and frequency.

As a general rule, any individual gift or hospitality with a value above £100, or any cumulative value above £250 per recipient per calendar year, must be pre-approved in writing by a director and recorded in the gifts and hospitality register. Where you are unsure, ask before giving or accepting.

6. Public officials

Special care must be taken in any dealing with a public official (including foreign public officials). No gift, hospitality or other advantage may be given to a public official without prior written approval from a director.

7. Suppliers and third parties

TRM Flex carries out proportionate due diligence on suppliers and third parties acting on its behalf. Engagements with such parties include a contractual obligation to comply with anti-bribery laws and with this policy. We may decline to engage, or terminate, any third party that does not meet these standards.

8. Records and accounts

• All financial transactions must be accurately and transparently recorded.
• No off-the-books accounts or false documentation may be used.
• Expense claims relating to gifts, hospitality or payments to third parties must be submitted with sufficient detail to enable review.

9. Reporting concerns

If you suspect bribery or corruption, raise it immediately under our Whistleblowing Policy or by email to hello@trmflex.com with subject prefix [Anti-Bribery]. You will not suffer detriment for reporting a genuine concern in good faith.

10. Breach

Breach of this policy is a serious matter. For employees, it may lead to disciplinary action up to and including summary dismissal. For contractors and suppliers, it may lead to immediate termination of the contract. Conduct breaching the Bribery Act 2010 may also be reported to the appropriate authorities.

11. Review

This policy is reviewed at least every 12 months and updated when necessary.