Supplier Anti-Bribery and Corruption Policy

1. Document Control

2. Purpose

EnableAll Limited is committed to conducting business ethically, transparently, and in compliance with all applicable anti-bribery and anti-corruption laws.

This policy sets out the minimum standards and expectations for suppliers, contractors, consultants, and other third parties who work with, for, or on behalf of EnableAll Limited.

The purpose of this policy is to:

• Prevent bribery and corruption in the supply chain
• Ensure compliance with UK anti-bribery legislation
• Protect EnableAll Limited from legal, financial, and reputational risk

3. Scope

This policy applies to all suppliers, contractors, consultants, agents, intermediaries, and any other third parties who provide goods or services to EnableAll Limited.

For the avoidance of doubt, this policy applies in addition to any contractual obligations and does not replace any legal duties.

4. Policy Statement

EnableAll Limited operates a zero-tolerance approach to bribery and corruption.

Suppliers must not engage in any form of bribery or corruption, whether directly or indirectly, on behalf of EnableAll Limited or in connection with its business.

Any breach of this policy may result in termination of contracts, exclusion from future business, and/or reporting to relevant authorities.

5. Roles and Responsibilities

6. Legislative Framework

This policy is informed by and aligned with the following UK legislation:

• Bribery Act 2010
• Proceeds of Crime Act 2002
• Fraud Act 2006

7. Definitions

Bribery
The offering, promising, giving, requesting, or accepting of an advantage intended to induce or reward improper performance of a function or activity.

Facilitation Payment
A payment made to secure or speed up routine government action. Facilitation payments are prohibited.

Supplier
Any individual or organisation that supplies goods or services to EnableAll Limited.

8. Prohibited Conduct

Suppliers must not:

• Offer, give, request, or accept bribes of any kind
• Make facilitation payments
• Offer anything of value to improperly influence a business decision
• Engage in bribery involving public officials or their associates

9. Gifts, Hospitality, and Expenses

Gifts and hospitality must:

• Be modest, reasonable, and infrequent
• Never be offered to influence decision-making
• Not create a conflict of interest or risk reputational damage

Gifts or hospitality to public officials are strongly discouraged and must never be offered where they could be perceived as an inducement.

10. Political and Charitable Contributions

EnableAll Limited does not make political donations.

Suppliers must not make political or charitable contributions on behalf of EnableAll Limited.

Charitable donations must never be made with the expectation of receiving an improper business advantage.

11. Due Diligence and Compliance

EnableAll Limited reserves the right to:

• Conduct due diligence on suppliers prior to appointment
• Request confirmation of compliance with this policy
• Audit supplier compliance where appropriate

Suppliers must cooperate fully with any such requests.

12. Reporting Concerns

Suppliers must report any actual or suspected breach of this policy immediately to their EnableAll Limited contact.

EnableAll Limited will ensure that no supplier suffers detrimental treatment for raising concerns in good faith.

13. Consequences of Breach

Any breach of this policy may result in:

• Termination of contractual arrangements
• Exclusion from future tendering opportunities
• Reporting to law enforcement or regulatory authorities

14. Related Policies

• Anti-Fraud, Bribery, and Corruption Policy
• Whistleblowing Policy
• Gifts and Hospitality Procedure

15. Review and Maintenance

This policy will be reviewed annually or sooner if required due to legislative or organisational change.

16. Revision History