Contents

1. What Does This Policy Cover?
2. Policy Statement
3. Who Is Covered by the Policy?
4. Definition of Bribery
5. What Is and Is Not Acceptable
   a. Gifts and Hospitality
   b. Facilitation Payments and Kickbacks
   c. Political Contributions
   d. Charitable Contributions
6. Employee Responsibilities
7. What Happens If I Need to Raise a Concern?
   a. How to Raise a Concern
   b. What to Do If You Are a Victim of Bribery or Corruption
   c. Protection
8. Training and Communication
9. Record Keeping
10. Monitoring and Reviewing

1. What Does This Policy Cover?

1.1 This anti-bribery policy sets out the responsibilities of White’s Scaffolding Ltd and those who work for us in upholding our zero-tolerance stance on bribery and corruption.

1.2 It provides guidance to help employees recognise and deal with bribery and corruption issues and understand their responsibilities under the Bribery Act 2010.

1.3 The Company complies with relevant competition law, which promotes fair and open competition. Competition authorities have wide powers to investigate breaches, including the ability to conduct dawn raids on business and personal premises.

Requirement

This policy ensures that all employees and persons engaged by White’s Scaffolding Ltd understand potential competition law issues and know how to escalate them appropriately.

2. Policy Statement

2.1 White’s Scaffolding Ltd conducts business ethically and honestly, enforcing systems that prevent bribery. We have a zero-tolerance policy for corrupt activities.

2.2 We will uphold all anti-bribery and corruption laws in the UK and internationally, including the Bribery Act 2010.

2.3 Bribery and corruption are serious offences. Individuals may face imprisonment and significant fines. Organisations may face unlimited penalties, exclusion from public contracts and reputational damage. Preventing bribery is therefore essential to our operations.

3. Who Is Covered by the Policy?

3.1 This policy applies to all employees (temporary, permanent, full-time, part-time), consultants, contractors, trainees, agency workers, volunteers, interns, agents, sponsors, associated third parties and subsidiaries.

3.2 “Third party” refers to any individual or organisation that White’s Scaffolding Ltd interacts with, including clients, customers, suppliers, distributors, business partners, government bodies, officials, advisers and representatives.

3.3 All arrangements with third parties must include contractual terms requiring compliance with anti-bribery and corruption standards.

4. Definition of Bribery

4.1 Bribery is offering, giving, promising, requesting, accepting or receiving something of value to improperly influence a decision or action.

4.2 A bribe is any inducement or reward intended to gain commercial, regulatory or personal advantage.

4.3 Accepting a bribe is illegal, not just offering one.

4.4 Employees must not engage in bribery directly, indirectly or through third parties, nor may they bribe foreign officials. Any uncertainty must be referred to the compliance manager.

5. What Is and Is Not Acceptable

This section covers:

• Gifts and hospitality
• Facilitation payments
• Political contributions
• Charitable contributions

5.2 Gifts and Hospitality

White’s Scaffolding Ltd accepts appropriate gestures of goodwill where:

a. The gesture is not intended to influence a business decision or reward favourable treatment.
b. No return favour is expected.
c. It complies with local law.
d. It is given in the Company’s name, not personally.
e. It does not involve cash or cash equivalents.
f. It is appropriate for the situation.
g. Its timing and value are reasonable.
h. It is not given secretly.
i. It is not aimed at influencing an individual unfairly.
j. It does not exceed the compliance manager’s approved value (usually >£100).
k. It is not given to or accepted from government officials without approval.

5.3 Gifts that cannot be politely refused due to cultural reasons may be accepted but must be declared.

5.4 The Company recognises cultural differences in business gift practices.

5.5 All gifts from suppliers must be disclosed.

5.6 When in doubt, employees must consult the compliance manager.

5.7 Facilitation Payments and Kickbacks

• The Company does not accept or make facilitation payments.
• Kickbacks are strictly prohibited.
• Facilitation payments are unofficial payments made to speed up routine actions.

If a situation arises where refusing a payment endangers personal safety:

a) Keep the payment as small as possible.
b) Request a receipt.
c) Record the incident.
d) Report it immediately to your line manager.

5.10 Political Contributions

White’s Scaffolding Ltd does not make political donations of any kind.

5.11 Charitable Contributions

• The Company supports legitimate charitable activity.
• Donations must be legal, ethical and never used to disguise bribery.
• All charitable contributions must be approved by the compliance manager.

6. Employee Responsibilities

6.1 Employees must read, understand and comply with this policy.

6.2 Employees are responsible for preventing, detecting and reporting bribery or corruption.

6.3 Any suspicion must be reported to the compliance manager.

6.4 Breaches may result in disciplinary action, including dismissal for gross misconduct.

7. What Happens If I Need to Raise a Concern?

7.2 How to Raise a Concern

Employees should raise concerns at the earliest opportunity. If unsure whether behaviour is bribery or corruption, they must speak to their line manager, compliance manager, director or the Head of Governance and Legal.

7.3 Employees will be made familiar with whistleblowing procedures.

7.4 What to Do If You Are a Victim of Bribery or Corruption

Inform the compliance manager immediately if:

• You are offered a bribe
• You are asked to make a bribe
• You suspect future bribery
• You believe you are a victim of corruption

Concerns may also be reported to the Competition and Markets Authority (CMA):

• Online – Report an issue to the CMA
• Phone – 020 3738 6000
• Email – general.enquiries@cma.gov.uk

7.5 Protection

7.6 White’s Scaffolding Ltd will support anyone who refuses to accept a bribe or who reports concerns in good faith.

7.7 No one will suffer dismissal, disciplinary action, threats or unfair treatment for doing so.

7.8 Employees who believe they have been treated unfairly must report it immediately.

8. Training and Communication

• All new employees receive training on this policy during induction.
• Employees must formally confirm annual compliance.
• Suppliers, contractors and third parties will be informed of the Company’s zero-tolerance approach.
• Additional training will be provided where risk exposure is higher.

9. Record Keeping

White’s Scaffolding Ltd will maintain complete and accurate financial records. All hospitality and gifts must be recorded and reviewed by management.

10. Monitoring and Reviewing

10.1 The compliance manager will monitor the effectiveness of this policy.

10.2 Internal systems and controls will be audited regularly.

10.3 Improvements will be implemented promptly.

10.4 This policy may be amended at any time to improve effectiveness.

Name: Lewis White
Position: Director
Date: 10th April 2025