Anti Bribery and Corruption Policy
1. Policy
Datalaw is committed to promoting and maintaining the highest possible ethical, legal, and professional standards in all business operations. Datalaw’s reputation for integrity is vital to its continued success. This Policy is designed to safeguard these values.
Datalaw has a zero-tolerance approach to bribery and corruption and is committed to acting fairly, transparently and with integrity in all dealings and relationships, wherever in the world the business operates. Datalaw will implement and enforce effective anti-bribery systems, including those required under modern corporate governance, ESG, and supply-chain transparency standards.
This Policy applies to all permanent and temporary Employees of Datalaw (including intermediaries, subsidiaries, and associated companies). It also applies to any individual or corporate entity associated with Datalaw or performing services for or on behalf of Datalaw (“Associated Persons”), including but not limited to Directors, Agency Workers, Casual Workers, Contractors, Consultants, Seconded Employees, Agents, Suppliers, and Sponsors.
All Employees and Associated Persons must comply with the principles in this Policy and complete any mandatory training issued under it.
2. Legal and Regulatory Obligations
This Policy is based primarily on the Bribery Act 2010, as well as relevant obligations under:
- Economic Crime and Corporate Transparency Act 2023 (ongoing implementation through 2025)
- Proceeds of Crime Act 2002 (as amended)
- Fraud Act 2006
- Companies Act 2006 (governance and reporting expectations)
- Modern Slavery Act 2015 (supply-chain integrity relevant to corruption risk)
- International legislation in jurisdictions where Datalaw operates or engages partners, including but not limited to the US Foreign Corrupt Practices Act (FCPA) and EU anti-corruption requirements.
A bribe is an inducement or reward offered, promised, requested or received to gain any commercial, contractual, regulatory, or personal advantage.
It is an offence to:
- Offer, promise, or give a financial or other advantage intending to induce or reward improper conduct.
- Request, agree to receive, or accept an advantage for improper conduct.
- Bribe a foreign public official.
- Fail to prevent bribery by an associated person acting on behalf of the organisation.
Individuals can be held personally liable and may face imprisonment. Datalaw may incur unlimited fines, regulatory sanctions, and reputational damage.
3. Requirements
All Employees and Associated Persons must:
- Comply with all anti-bribery, anti-corruption, and financial crime legislation in every jurisdiction where business is conducted.
- Act honestly, responsibly, and with integrity.
- Safeguard Datalaw’s reputation by operating ethically and lawfully.
- Complete mandatory training and comply with due-diligence procedures.
- Report concerns promptly (see Section 6).
4. Bribery
Bribery in any form is strictly prohibited. Under no circumstances may you create or use accounts, budgets, or funds intended to enable, disguise, or facilitate improper payments.
Datalaw recognises that business practices vary across cultures; however, the standards in this Policy apply globally without exception.
If unsure whether conduct constitutes bribery, Employees must seek guidance from their Line Manager or the Compliance Lead.
5. Exceptions to Giving Gifts and Hospitality
Reasonable and proportionate business gifts or hospitality may be permitted only where all of the following conditions are met:
- The gift/hospitality is not intended to influence a third party improperly.
- It complies with local laws and Datalaw’s internal approval thresholds.
- It is given in Datalaw’s name, not a personal name.
- It does not include cash or cash equivalents.
- Its value and timing are appropriate and transparent.
- It is recorded in accordance with Datalaw’s gift-register procedure.
- It is approved in advance by a Senior Manager.
It is not acceptable to:
- Offer or receive gifts/hospitality in exchange for business advantage.
- Accept gifts/hospitality that create a conflict of interest.
- Provide any form of payment or benefit to a public official intended to influence their duties.
Facilitation payments (“speed payments”) are strictly prohibited, even where considered customary in a particular country.
6. Responsibility and Reporting Procedure
All Employees and Associated Persons have a contractual obligation to:
- Take reasonable steps to ensure compliance with this Policy.
- Prevent, detect, and report bribery, corruption, financial impropriety, or associated risks.
- Report concerns about any Employee or Associated Person offering, promising, giving, requesting, agreeing to receive, or accepting a bribe.
Reports should be made immediately to your Line Manager or the Compliance Lead.
Reports may also be made through Datalaw’s Whistleblowing Procedure, in line with enhanced whistleblower protections expected under evolving UK reforms (2024–2026).
Confidentiality will be preserved wherever practical. Datalaw prohibits any form of retaliation, victimisation, or disadvantage against anyone who raises concerns in good faith.
Datalaw may take internal disciplinary action, terminate contracts, or report matters to external agencies such as the Police, Serious Fraud Office (SFO), HMRC, or professional regulators.
All Employees must ensure that any contract entered into on behalf of Datalaw includes anti-bribery clauses with explicit consequences for non-compliance.
7. Record Keeping
Datalaw maintains strict financial controls and accurate accounting records. All Employees and Associated Persons must:
- Keep complete and accurate records of all transactions, gifts, hospitality, and expenses.
- Avoid informal, unrecorded, or “off-the-books” accounts or transactions.
- Ensure all invoices and receipts are legitimate, detailed, and transparent.
Digital systems, including AI-assisted financial tools where used, must comply with Datalaw’s data-governance and financial-crime controls.
8. Sanctions for Breach
Breaching this Policy may result in:
- Disciplinary action up to and including summary dismissal.
- Termination of contracts with Associated Persons.
- Civil or criminal proceedings.
- Reporting to professional bodies and regulatory authorities.
9. Monitoring Compliance
Datalaw’s Senior Leadership Team is responsible for:
- Overseeing and reviewing this Policy annually (or more frequently if law or risk profiles change).
- Monitoring effectiveness of anti-bribery controls, including due diligence and risk assessments.
- Reporting regularly to the Board of Directors.
The Company will continually evaluate risk areas, including emerging risks such as AI-generated fraud, supply-chain vulnerabilities, and heightened scrutiny from regulators.
10. Training
Datalaw will provide mandatory anti-bribery and corruption training for all Employees and appropriate training for Associated Persons. Refresher training will be issued periodically and whenever legislation or internal procedures change.
The Company’s zero-tolerance stance will be communicated to all business partners at the start of each business relationship and periodically thereafter.
11. Potential Risks
The following non-exhaustive examples may indicate bribery or corruption risk and must be reported:
- A third party insists on a commission or fee before signing a contract or performing a government process.
- Requests for cash payments, unusual payment methods, or refusal to provide receipts or documentation.
- Requests for additional or unexplained fees to “facilitate” or “speed up” services.
- Demands for extravagant or inappropriate gifts or hospitality.
- Offers of personally lavish gifts or hospitality to Employees.
- Invoices that appear irregular, excessive, vague, or inconsistent.
- Third parties with opaque ownership structures or unwillingness to undergo due-diligence checks.
- Irregularities identified through AI-assisted or automated financial reviews.
Employees must also be alert to:
- Conflicts of interest.
- Unusual subcontracting or intermediary arrangements.
- Suppliers or agents in high-risk jurisdictions.
- Digital or cyber-enabled bribery, including misuse of AI, deepfakes, or fraudulent digital authorisation requests.
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Reviewed Date |
04th December 2025 |
Next Review Due Date |
04th December 2026 |
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Reviewed by |
Sarah Parker |
Signature |
Sarah Parker |