Anti-Bribery & Corruption Policy

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Purpose

Cambianz Limited (“the Company”) is committed to conducting all business honestly, fairly and with integrity. We have zero tolerance for bribery or any form of corrupt practice.

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Scope

This policy applies to all employees, directors, contractors, consultants, agency staff, and anyone working on our behalf anywhere in the world.

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What Counts as Bribery

Offering, promising, giving, requesting or accepting anything of value to gain an improper business advantage, including facilitation payments, kickbacks or excessive gifts.

Key Requirements

• No Bribes or Facilitation Payments –Never offer or accept bribes, either directly or through a third party.
• Gifts & Hospitality –Modest, reasonable and infrequent hospitality is acceptable if it is transparent and for legitimate business purposes. Any gift or hospitality above£50 (or local equivalent) requires written approval from a director and entry into the Gifts & Hospitality Register.
• Third Parties – Conduct proportionate due diligence before engaging agents, suppliers or consultants.Contracts must include anti-bribery clauses.
• Political & Charitable Contributions– Must be approved by the Directors and never made with the intention of securing business advantage.
• Books & Records –Maintain accurate records of all payments and expenses.

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Raising Concerns

Employees and contractors must report suspected bribery to the Managing Director or via the confidential compliance email (compliance@cambianz.com). Retaliation against whistle-blowers is prohibited.

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Consequences of Breach

Disciplinary action up to dismissal, termination of contract, and possible referral to lawenforcement.

Responsibility & Review

The Director is responsible for implementing and reviewing this policy annually.

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EffectiveDate: 24 October 2024

Last review: 11 May 2026