Anti-Bribery & Anti-Corruption

Last Updated: 1st October 2025

1. Policy Statement

Bespoke Aero Ltd (“the Company”) is committed to conducting business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate.

The Company will uphold all laws relevant to countering bribery and corruption, including the Bribery Act 2010 of England and Wales, in respect of our conduct both in the UK and abroad.

2. Purpose of This Policy

This policy:

Sets out our responsibilities, and those of all persons working for us or on our behalf, in observing and upholding our position on bribery and corruption; and
Provides guidance on recognising and dealing with bribery and corruption issues.

Bribery and corruption are criminal offences. Individuals engaging in such conduct may face prosecution, fines, and imprisonment. The Company may also face unlimited fines, exclusion from tendering for public contracts, and serious reputational damage.

3. Scope

This policy applies to all individuals working for the Company at all levels, including directors, officers, employees, consultants, contractors, trainees, volunteers, casual workers, agency staff, and any third parties associated with the Company (together referred to as “Associated Persons”).

4. What is Bribery?

Bribery is offering, promising, giving, accepting, or soliciting an advantage as an inducement for an action that is illegal, unethical, or a breach of trust.

Examples include:

Offering or accepting cash or gifts to influence a business decision;
Providing excessive hospitality to secure a contract;
Facilitating payments (“kickbacks”) to speed up routine processes;
Awarding contracts or business advantages to friends, family, or connections improperly.

5. Gifts and Hospitality

This policy does not prohibit normal and appropriate hospitality given and received in the course of business, provided that it:

Is not made with the intention of influencing a third party to obtain or retain business, or to gain an improper advantage;
Complies with local laws;
Is given in the Company’s name, not in an individual’s name;
Is appropriate in the circumstances, reasonable in value, and infrequent in nature; and
Is openly declared and recorded.

Gifts or hospitality that could be perceived as excessive, lavish, or intended to secure influence are strictly prohibited.

6. Facilitation Payments and Kickbacks

The Company does not make, and will not accept, facilitation payments or “kickbacks” of any kind.

Facilitation payments are typically small, unofficial payments made to secure or expedite a routine governmental action. Kickbacks are typically payments made in return for a business favour or advantage. Both are strictly prohibited.

7. Donations

The Company does not make contributions to political parties. Charitable donations must be ethical, transparent, and approved in writing by senior management.

8. Responsibilities of Staff and Associated Persons

All employees and Associated Persons must read, understand, and comply with this policy.
The prevention, detection, and reporting of bribery and corruption is the responsibility of all those working for the Company or under its control.
Staff are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Any suspected bribery or corruption must be reported immediately under the Company’s reporting procedure (see Section 9).

9. Raising Concerns

Employees and Associated Persons are encouraged to raise concerns at the earliest possible stage if they believe or suspect that a conflict with this policy has occurred or may occur in the future. Concerns should be reported to an executive Director.

The Company is committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because they report in good faith their suspicion.

10. Record-Keeping

The Company will keep accurate financial records and have appropriate internal controls in place to evidence the business reason for payments to third parties.

All gifts and hospitality must be recorded in the Company’s Gifts and Hospitality Register.

11. Training and Communication

The Company will provide training to ensure that all employees and relevant Associated Persons understand and comply with this policy. The Company’s zero-tolerance position will be communicated to suppliers, contractors, agents, and business partners at the outset of our relationship with them.

12. Breaches of This Policy

Any employee who breaches this policy will face disciplinary action, which may result in dismissal for misconduct or gross misconduct. The Company may terminate its relationship with other Associated Persons if they breach this policy.

13. Review of This Policy

The Company’s Board of Directors will review this policy regularly to ensure its effectiveness, compliance with law, and alignment with best practice.

14. Governing Law

This policy is governed by and shall be construed in accordance with the laws of England and Wales.