1. Policy Statement

Simply 365 Limited (“the Company”) is committed to conducting all business activities ethically, transparently, and in compliance with applicable laws.

The Company has a zero-tolerance approach to bribery and corruption in any form, whether involving:

• Employees
• Directors
• Contractors
• Suppliers
• Agents
• Intermediaries
• Clients
• Public officials

This policy is designed to comply with the requirements and principles of the Bribery Act 2010.

2. Scope

This policy applies to:

• All employees (permanent, temporary, and contract)
• Directors and senior management
• Consultants and contractors
• Suppliers and service providers
• Any third party acting on behalf of the Company

Compliance with this policy is mandatory.

3. Definition of Bribery and Corruption

Bribery is offering, promising, giving, requesting, or accepting any financial or other advantage to induce or reward improper performance of a relevant function or activity.

Corruption includes any abuse of entrusted power for private gain.

This may include:

• Cash payments
• Gifts of excessive value
• Hospitality intended to influence decisions
• Facilitation payments
• Unlawful commissions
• Kickbacks
• Improper political or charitable contributions

4. Prohibited Conduct

The Company strictly prohibits:

• Offering or accepting bribes
• Requesting improper advantages
• Making facilitation payments
• Engaging in corrupt practices
• Concealing improper payments
• Using third parties to bypass anti-bribery controls

Employees must not:

• Offer anything of value to influence business decisions
• Accept gifts or hospitality that could create a conflict of interest
• Engage in conduct that could be perceived as improper

5. Gifts and Hospitality

Gifts and hospitality must:

• Be reasonable and proportionate
• Be transparent
• Not influence decision-making
• Comply with internal approval processes

Gifts of significant value must be declared to management.

Where there is doubt, employees must seek approval before accepting or offering gifts.

6. Third-Party Risk Management

The Company recognises that bribery risks can arise through third parties.

We therefore:

• Conduct appropriate due diligence on suppliers and partners
• Include anti-bribery clauses in contracts
• Require compliance with applicable anti-corruption laws
• Reserve the right to terminate relationships in case of breach

Particular attention is given to:

• Contractor networks
• Procurement arrangements
• Commission-based relationships
• Intermediaries

7. Public Sector Interactions

Where the Company engages with public bodies, regulators, or housing sector authorities:

• All interactions must be lawful and transparent
• No improper advantage may be offered or requested
• Records of engagements must be maintained where appropriate

8. Accounting and Record Keeping

The Company maintains accurate books and records to ensure:

• Transparency of financial transactions
• Proper authorisation of payments
• No hidden or undisclosed transactions
• Full compliance with financial controls

False or misleading records are strictly prohibited.

9. Reporting Concerns

Any employee, contractor, or third party who suspects bribery or corruption must report it immediately.

Reports may be made to:

• Line management
• Senior leadership
• Compliance representative

The Company will:

• Investigate concerns promptly
• Take appropriate corrective action
• Protect individuals who report concerns in good faith

Retaliation against whistleblowers is prohibited.

10. Consequences of Breach

Failure to comply with this policy may result in:

• Disciplinary action (up to and including dismissal)
• Termination of contracts
• Reporting to relevant authorities
• Civil or criminal proceedings

Bribery offences can carry significant penalties under the Bribery Act 2010, including personal liability.

11. Training and Awareness

The Company will provide appropriate anti-bribery awareness to:

• Senior management
• Procurement personnel
• Contractor management teams

Training ensures employees understand:

• Bribery risks
• Warning signs
• Reporting procedures
• Their responsibilities under this policy

12. Monitoring and Review

This policy will be:

• Reviewed at least annually
• Updated as necessary to reflect legal or operational changes
• Supported by proportionate internal controls

The Board of Directors retains oversight responsibility.

13. Continuous Commitment

Simply 365 Limited is committed to maintaining the highest ethical standards in all business dealings and fostering a culture of integrity, transparency, and accountability.

14. Contact Us

If you have any questions about this Anti Bribery or Corruption Policy then please contact:

Simply 365 Limited
Registered Office: C/O Partners In Enterprise Ltd Ground & Lower Ground Floor, 9 St Georges Place, Brighton, United Kingdom, BN1 4GB

Email: hello@simply365.co.uk
Phone: 0333 052 7218