Policy Statement

Workwear Supermarket is committed to conducting business honestly, ethically and with integrity. We maintain a zero-tolerance approach to bribery and corruption in any part of our business.

This policy sets out the principles, expectations and procedures by which Workwear Supermarket seeks to prevent, detect and respond to bribery, corruption and improper business conduct.

This policy applies to all employees, workers, officers, contractors, agents, representatives, intermediaries, suppliers and third parties who act for or on behalf of Workwear Supermarket.

Legal & Regulatory Framework

Workwear Supermarket requires compliance with all applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010.

Where local laws, client requirements or supplier standards are stricter than this policy, the stricter requirement should be followed. Where laws are weaker or silent, this policy will serve as the minimum standard expected by Workwear Supermarket.

Definition of Bribery & Corruption

Bribery means offering, promising, giving, accepting or requesting an advantage to improperly influence the actions, decisions or behaviour of another person or organisation.

This may include money, gifts, hospitality, entertainment, loans, services, favours, discounts, commissions or any other benefit intended to gain or retain business or secure an unfair commercial advantage.

Bribery may be direct or indirect, including where improper payments or benefits are provided through a third party.

Examples may include:

• Cash payments, secret commissions or kickbacks.
• Gifts, meals, entertainment or travel expenses intended to influence a decision.
• Disproportionate or unusually frequent hospitality from suppliers or potential suppliers.
• Using company services, stock, equipment or assets for private benefit without approval.
• Providing benefits to a family member or close contact of a decision-maker.
• Payments made to speed up or secure routine official actions, licences, permits or approvals.

Consequences of Breach

Any breach of this policy, whether intentional or negligent, will be treated as a serious matter. Employees who breach this policy may be subject to disciplinary action, up to and including dismissal.

Third parties, suppliers, contractors, agents or intermediaries who fail to comply with this policy may have their relationship or contract with Workwear Supermarket terminated.

Prohibited Conduct & Controls

Illegal Payments

No funds, resources, stock, services or assets of Workwear Supermarket may be used, directly or indirectly, for bribery, kickbacks, facilitation payments or any other corrupt practice.

Gifts, Hospitality & Entertainment

Gifts and hospitality must always be proportionate, transparent, reasonable and for legitimate business purposes.

• Gifts must not be given or accepted where they could improperly influence a business decision.
• Cash or cash-equivalent gifts must not be offered or accepted.
• Gifts or hospitality from suppliers or potential suppliers must be treated with caution.
• Any gift or hospitality above an agreed threshold must be approved and recorded.
• Hospitality involving public officials must be avoided unless specifically approved by management.

Facilitation Payments

Workwear Supermarket does not permit facilitation payments. These are payments made to speed up or secure routine actions, such as permits, licences, customs clearance or other administrative processes.

Supplier, Manufacturer & Third-Party Compliance

Workwear Supermarket expects suppliers, manufacturers, contractors, agents and business partners to operate in accordance with all applicable laws relating to bribery, corruption, employment, modern slavery and ethical business conduct.

When appointing or reviewing third parties, Workwear Supermarket may consider:

• Ownership structure and business reputation.
• Previous conduct, compliance history and ethical working practices.
• Potential conflicts of interest.
• Relevant anti-bribery, corruption and modern slavery policies.
• Written confirmation that the third party will comply with applicable laws and company standards.

Procurement & Purchasing Controls

Employees involved in purchasing products, services, equipment or supplier arrangements must act in the best interests of Workwear Supermarket.

• Purchasing decisions should be based on quality, value, service, reliability and business requirements.
• Appropriate approvals should be obtained where required.
• Employees must avoid conflicts of interest or declare them immediately if they arise.
• Employees must not accept gifts, incentives or benefits that could influence purchasing decisions.
• Payments to suppliers must be transparent, properly authorised and made through traceable methods.

Dealings with Public Officials & Political Bodies

Any dealings with government bodies, public officials, regulators or political organisations must be lawful, transparent and free from improper influence.

Under no circumstances should gifts, entertainment, payments or benefits be offered to public officials in order to secure a business advantage.

Charitable Donations & Political Contributions

Workwear Supermarket does not make political contributions.

Charitable donations must be properly approved and documented. They must never be used as a way of disguising improper payments, inducements or benefits.

Reporting & Whistleblowing

Employees and third parties are encouraged to report any actual or suspected bribery, corruption, malpractice or unethical conduct.

Reports should be made to management as soon as possible. Concerns will be reviewed appropriately and treated seriously.

• Employees must not ignore suspected bribery or corruption.
• Reports will be handled as confidentially as reasonably possible.
• Employees are expected to cooperate with any investigation.
• Workwear Supermarket will not tolerate victimisation of anyone who raises a genuine concern.

Risk Assessments & Application

Workwear Supermarket will assess bribery and corruption risks relevant to its business activities, supplier relationships, procurement processes and customer or third-party dealings.

Risk assessments help inform controls, monitoring and internal review activity. Higher-risk activities may be subject to additional checks, approvals or management oversight.

Training & Awareness

Employees will be made aware of this policy and their responsibilities in relation to bribery and corruption. Additional guidance may be provided to employees in roles involving procurement, sales, finance, supplier relationships or third-party dealings.

• Employees should understand what bribery and corruption may look like.
• Employees should know how to report concerns.
• Employees involved in higher-risk roles may receive additional training or guidance.
• Policy awareness may be refreshed periodically or when business risks change.

Gifts, Hospitality & Donations Registers

Workwear Supermarket may maintain records of gifts, hospitality, charitable donations and any other matters that require transparency or management approval.

Records may include:

• Name of giver or receiver.
• Date offered or received.
• Nature and estimated value of the gift or hospitality.
• Reason or business purpose.
• Approval details where required.

Declaration of Interests

Employees in roles that may be vulnerable to influence, including purchasing, supplier management, sales, finance or management roles, must declare actual or potential conflicts of interest.

Any new conflict that arises during employment or engagement must be reported to management as soon as possible.

Business Expansion & New Supplier Due Diligence

Where Workwear Supermarket enters into new supplier relationships, partnerships or significant business arrangements, appropriate checks may be carried out to identify bribery, corruption, ethical or compliance risks.

Where concerns are identified, management will determine whether additional controls, supplier assurances, corrective actions or termination of the relationship are required.

Policy Ownership, Review & Monitoring

This policy is owned by the Managing Director or a designated senior person within Workwear Supermarket.

The policy will be reviewed at least every two years, or sooner where there are significant changes to legislation, business operations, supplier arrangements or identified bribery and corruption risks.

Approval & Signature

Approved By: J. Ross

Position: Managing Director

Effective Date: Jun 2025

Next Review: September 2027