1. Purpose

Carter Fleet is committed to conducting business with honesty, integrity, and transparency. We have a zero-tolerance approach to bribery and corruption in any form, whether in the UK or overseas. This policy outlines our responsibilities and the standards expected of everyone working for or with us.

2. Scope

This policy applies to all individuals working with or on behalf of Carter Fleet, including the founder, contractors, freelancers, employees or partners.

3. What is bribery?

Bribery means offering, promising, giving, requesting, or accepting anything of value to improperly influence a decision, secure a business advantage, or reward improper performance. This includes:

• Cash payments or “kickbacks”

• Gifts, hospitality, or travel of excessive value

• Favours or job offers for personal gain

4. Our rules

No bribes. We never offer, give, request, or accept bribes in any form.

Reasonable hospitality only. Business gifts and hospitality must be modest, proportionate, and clearly for legitimate business purposes.

Follow the law. All dealings must comply with the UK Bribery Act 2010 and relevant local laws abroad.

Third parties. We will not work with agents, suppliers, or partners who engage in bribery or corrupt practices.

Transparency. Any potential conflict of interest or high-value gift must be declared to the founder.

5. Facilitation payments

We do not make facilitation payments (small unofficial payments to speed up routine processes).

6. Responsibilities

The founder is responsible for ensuring this policy is understood and followed.

All staff, contractors, and partners must report suspected bribery or corruption directly to the founder.

Concerns will be investigated promptly and confidentially.

7. Breaches

Breaches of this policy may result in termination of contracts, refusal of future work, and possible criminal prosecution.

8. Review

This policy will be reviewed annually by the founder and updated as necessary to reflect changes in law or business operations.