Anti-Bribery & Anti-Corruption Policy

Company name: Be Clean Services Limited
Company number: 15045016
Director: Ludiata Wasansua
Registered office: Flat 3, 44a Cavendish Street, Manchester, M15 6BQ

Policy owner: Director
Approval authority: Director, Ludiata Wasansua
Effective date: 14 October 2026
Review date: 14 October 2027
Version: 1.0

1. Policy Statement

Be Clean Services Limited (“the Company”) is committed to conducting all business activities honestly, fairly, transparently and in compliance with applicable UK laws and regulations.

The Company adopts a zero-tolerance approach to bribery, corruption, fraud and other improper business practices. The Company will not offer, promise, give, request, agree to receive or accept a bribe, whether directly or indirectly, in any circumstances.

The Company expects all employees, directors, agency workers, subcontractors, suppliers, consultants, agents and other persons acting on its behalf to uphold the highest standards of integrity.

No person will be permitted to engage in bribery or corruption to secure a cleaning contract, retain a customer, obtain preferential treatment, influence a procurement decision or gain any other improper business advantage.

The Company is committed to implementing proportionate procedures to prevent bribery, identifying and managing risks, investigating concerns and taking appropriate action where misconduct is identified.

2. Purpose

The purpose of this policy is to:

Prevent bribery and corruption in all Company business activities.
Establish clear rules governing gifts, hospitality, payments, commissions and business dealings.
Ensure that employees and associated persons understand their responsibilities.
Protect the Company, its clients, employees, suppliers and business partners from bribery-related risks.
Support compliance with the Bribery Act 2010 and other applicable legal requirements.
Provide a clear process for reporting and investigating suspected bribery or corruption.

3. Scope

This policy applies to all persons working for, employed by, contracted to or otherwise representing Be Clean Services Limited, including:

The director and Company management.
Permanent and temporary employees.
Cleaning operatives and supervisors.
Agency workers and labour providers.
Subcontractors and self-employed contractors.
Suppliers, consultants, intermediaries and business representatives.
Any other person performing services for or on behalf of the Company.

The policy applies to all Company activities, whether conducted at the registered office, clients’ premises, commercial sites, residential properties, public-sector premises or elsewhere.

All relevant persons must comply with this policy regardless of their position or seniority.

4. Legal Framework

The Company will comply with applicable UK anti-bribery and anti-corruption legislation, particularly the Bribery Act 2010.

The Act establishes offences relating to:

Offering, promising or giving a bribe.
Requesting, agreeing to receive or accepting a bribe.
Bribing a foreign public official.
Failure by a relevant commercial organisation to prevent bribery by a person associated with it.

The Company recognises that it may be liable where an associated person bribes another person intending to obtain or retain business or a business advantage for the Company. The statutory defence under section 7 concerns having adequate procedures designed to prevent such bribery; the existence of this policy alone does not guarantee that the defence will be available.

The Company will therefore seek to implement and maintain practical, proportionate and effective anti-bribery procedures appropriate to the nature and scale of its operations.

5. Definition of Bribery and Corruption

Bribery generally involves offering, promising, giving, requesting, agreeing to receive or accepting a financial or other advantage with the intention of inducing or rewarding improper performance or influencing a person improperly.

Bribery may involve cash, gifts, hospitality, discounts, services, employment opportunities, commissions, favours, donations or any other advantage.

Corruption includes dishonest or improper conduct involving the abuse of entrusted power, position or authority for private or business gain.

Examples relevant to the Company include:

Paying a facilities manager personally to award the Company a cleaning contract.
Offering cash or gifts to a client’s employee in exchange for confidential tender information.
Giving an undisclosed commission to a person responsible for selecting cleaning contractors.
Accepting personal benefits in return for favouring a particular supplier.
Offering an inducement to overlook poor cleaning standards or contractual breaches.
Making an improper payment to secure access, permits or approvals.
Using a third party to make a payment that the Company would not be permitted to make directly.

Bribery may occur in both the public and private sectors. It may be committed directly or through an intermediary.

6. Prohibited Conduct

The Company strictly prohibits the following activities.

6.1 Offering or Giving Bribes

No person acting for or on behalf of the Company may offer, promise or give money, gifts, hospitality, favours or any other advantage to improperly influence a business decision.

6.2 Requesting or Accepting Bribes

No person may request, agree to receive or accept a bribe in connection with their work for the Company.

Employees and contractors must not use their position to obtain personal benefits from customers, suppliers, colleagues or subcontractors.

6.3 Facilitation Payments

Facilitation payments are prohibited. These are unofficial payments made to secure or speed up routine actions or services.

No person may make such a payment to obtain access to a site, accelerate an approval, avoid a legitimate process or secure preferential treatment.

Any demand for a facilitation payment must be reported to the Director as soon as reasonably practicable.

If a person reasonably believes that an immediate payment is necessary to protect themselves or another person from a threat to their safety, they should prioritise personal safety, avoid confrontation where possible and report the incident as soon as it is safe to do so. Any payment must be accurately recorded and reviewed.

6.4 Kickbacks and Improper Commissions

The Company prohibits kickbacks, undisclosed commissions and secret payments connected with the award or performance of contracts.

All legitimate commissions, referral fees and similar arrangements must be transparent, commercially justifiable, properly authorised and accurately recorded.

6.5 Improper Use of Company Funds

Company money, assets, equipment, services and resources must not be used to fund bribes, conceal improper payments or provide unauthorised personal benefits.

6.6 Bribery Through Third Parties

No person may use an agent, subcontractor, supplier, consultant or other intermediary to carry out an activity prohibited by this policy.

A person must not deliberately ignore warning signs that an intermediary may be involved in bribery.

7. Gifts and Hospitality

The Company recognises that modest, proportionate and legitimate business hospitality may be appropriate in certain circumstances. However, gifts and hospitality must never be used to influence a decision improperly or create an obligation.

All gifts and hospitality must be reasonable, transparent, infrequent and appropriate to the business relationship.

The following rules apply:

Cash and cash equivalents, including gift cards intended as personal rewards, must not be offered or accepted as business gifts.
Gifts or hospitality intended to influence a tender, contract award, inspection or payment decision are prohibited.
Gifts and hospitality must not be offered or accepted during a procurement or tendering process where they could create an actual or perceived conflict.
Lavish, excessive, secretive or inappropriate hospitality is prohibited.
Gifts and hospitality involving public officials require particular caution and must not be offered without the Director’s prior written approval and confirmation that the arrangement is lawful.
Any gift or hospitality that may reasonably be perceived as improper must be declined or referred to the Director.

All gifts and hospitality offered or received must be recorded where they are more than trivial or where there is any doubt about their appropriateness.

The Director must approve any proposed gift or hospitality that presents a potential bribery risk. Approval must be documented before the arrangement takes place, wherever practicable.

8. Donations, Sponsorship and Charitable Contributions

The Company may support legitimate charitable, community or sponsorship activities where there is a genuine business or social purpose.

Donations and sponsorship must not be used to secure contracts, influence decision-makers or provide indirect benefits to individuals in exchange for business advantages.

All such payments must:

Be made to legitimate and identifiable recipients.
Have a clear and documented purpose.
Be approved in advance by the Director.
Be supported by appropriate records and evidence of payment.
Be reviewed for conflicts of interest and bribery risks.

No donation or sponsorship payment may be made in response to a request that appears linked to a contract award or other improper business advantage.

9. Conflicts of Interest

All persons covered by this policy must avoid actual, potential or perceived conflicts between their personal interests and the interests of the Company.

Conflicts may arise where a person:

Has a personal or family relationship with a customer, supplier or subcontractor.
Has a financial interest in a business seeking work from the Company.
Receives personal benefits from a client or supplier.
Participates in a procurement or recruitment decision involving a close associate.
Uses confidential Company or client information for personal gain.

Any actual or potential conflict must be disclosed promptly to the Director and recorded where appropriate.

The Company will consider suitable safeguards, including withdrawal from decisions, independent review or reassignment of responsibilities.

10. Procurement, Contracts and Customer Relationships

The Company will conduct procurement and contract-related activities fairly and transparently.

When seeking, negotiating or performing cleaning contracts, the Company will:

Provide accurate and truthful information about its services, prices, qualifications and capabilities.
Avoid improper inducements to secure contracts or extensions.
Respect confidential tendering and procurement information.
Maintain appropriate records of quotations, tenders, negotiations and contract approvals.
Ensure that payments to suppliers and subcontractors are supported by legitimate business purposes.
Avoid secret arrangements or undisclosed personal benefits.
Raise concerns about suspicious requests for payments, gifts or confidential information.

No employee or representative may offer an improper benefit to a client, property manager, procurement officer, facilities manager or other decision-maker to secure or retain business.

11. Suppliers, Subcontractors and Other Associated Persons

The Company expects its suppliers, subcontractors, agents and other associated persons to operate ethically and comply with applicable anti-bribery laws.

Where proportionate to the level of risk, the Company will undertake appropriate checks before engaging third parties. These checks may include:

Confirming the identity and legitimacy of the proposed supplier or subcontractor.
Assessing the services to be provided and the commercial justification for the arrangement.
Reviewing relevant references, qualifications and business information.
Checking proposed fees, commissions and payment arrangements for unusual or unexplained features.
Identifying potential conflicts of interest.
Communicating the Company’s anti-bribery expectations.
Including suitable anti-bribery provisions in contracts where appropriate.

The Company will not knowingly engage a third party to facilitate bribery. Any credible concern about a third party must be referred to the Director for assessment and appropriate action.

12. Financial Controls and Record Keeping

The Company will maintain accurate, complete and transparent financial and business records.

All transactions must be properly documented and recorded in accordance with the Company’s normal accounting procedures and applicable legal requirements.

The following practices are prohibited:

False, misleading or incomplete accounting entries.
Unrecorded cash payments or secret accounts.
Fictitious invoices or expenses.
Payments unsupported by a legitimate business purpose.
Misdescription of gifts, hospitality, commissions or other expenses.
Splitting payments to avoid approval requirements.
Payments to unrelated third parties or unusual accounts without a satisfactory explanation and appropriate authorisation.

Invoices, receipts, contracts, purchase orders, expense claims, payment records and relevant approvals must be retained in accordance with the Company’s record-retention arrangements.

The Director is responsible for ensuring that appropriate financial controls are maintained.

13. Responsibilities

13.1 The Director

The Director, Ludiata Wasansua, has overall responsibility for implementing and overseeing this policy.

The Director will:

Demonstrate commitment to ethical business conduct.
Ensure that the policy is communicated to relevant persons.
Assess bribery risks appropriate to the Company’s activities.
Approve gifts, hospitality, donations and other transactions where required.
Ensure concerns are taken seriously and investigated appropriately.
Take reasonable steps to address identified weaknesses.
Review the policy periodically and update it when necessary.

13.2 Employees and Workers

All employees and workers must:

Read, understand and comply with this policy.
Act honestly and professionally.
Refuse to participate in bribery or corrupt practices.
Complete any required training or policy acknowledgement.
Report suspected bribery, improper payments or other concerns promptly.
Cooperate honestly with authorised investigations.

13.3 Suppliers and Subcontractors

Suppliers and subcontractors must comply with applicable anti-bribery laws and the requirements communicated to them by the Company.

They must not offer, request or accept improper advantages in connection with services provided to or on behalf of the Company.

14. Reporting Suspected Bribery or Corruption

Any person who suspects, witnesses or becomes aware of possible bribery or corruption must report the matter promptly.

Reports should be made directly to:

Ludiata Wasansua, Director
Be Clean Services Limited
Flat 3, 44a Cavendish Street, Manchester, M15 6BQ

A report may concern conduct by an employee, director, supplier, subcontractor, customer, agent or any other person associated with the Company.

Reports should include, where available:

A description of the suspected conduct.
The date and location of the incident.
The people or organisations involved.
Details of any payment, gift, request or other advantage.
Relevant documents, messages, invoices or other evidence.
Any immediate risks or concerns.

A person does not need to prove that bribery has occurred before reporting a genuine concern. Suspicions should be raised honestly and in good faith.

If the concern involves the Director, or the person reporting it reasonably believes that reporting internally would be inappropriate or unsafe, they may seek independent legal advice or report the matter to an appropriate external authority.

15. Whistleblowing and Protection from Retaliation

The Company will take reports of suspected bribery seriously and handle them as sensitively as reasonably practicable.

The Company will not tolerate retaliation against anyone who raises a genuine concern in good faith or assists with an authorised investigation.

Retaliation may include dismissal, threats, harassment, intimidation, disadvantageous treatment or other adverse action because a concern has been raised.

Confidentiality will be maintained where reasonably practicable and consistent with a fair investigation and applicable legal obligations. Absolute confidentiality cannot be guaranteed.

The Company will consider the protections available under applicable whistleblowing legislation where the relevant legal requirements are met.

Knowingly making a malicious or deliberately false allegation may result in disciplinary or other appropriate action.

16. Investigation of Concerns

All credible reports of suspected bribery or corruption will be assessed promptly and fairly.

Depending on the circumstances, the Company may:

Record the allegation and assess the immediate risks.
Preserve relevant documents, financial records and communications.
Appoint an appropriate person to conduct an impartial investigation.
Interview relevant individuals and review available evidence.
Take proportionate interim measures where necessary.
Document findings and decide on appropriate corrective action.
Refer suspected criminal conduct to the appropriate authorities where warranted.

Investigations will be conducted with due regard to confidentiality, fairness, applicable employment obligations and data protection requirements.

No person may destroy evidence, interfere with witnesses or obstruct an investigation.

17. Training and Communication

The Company will communicate this policy to relevant employees and associated persons.

Appropriate guidance or training will be provided according to the level of bribery risk, the person’s responsibilities and the nature of the work undertaken.

Training and communication may cover:

Recognising bribery and corruption.
Gifts, hospitality and conflicts of interest.
Procurement and contract-related risks.
Dealing with suppliers and subcontractors.
Financial record keeping.
Reporting concerns and protection from retaliation.

The Company will seek to ensure that relevant persons understand how the policy applies to their work.

18. Risk Assessment, Monitoring and Review

The Company will assess bribery risks proportionately to its business activities, size and operating environment.

Relevant risks may include contract procurement, subcontracting, supplier selection, customer relationships, unusual payment requests and interactions with public-sector customers or officials.

The Company will periodically review whether its controls are appropriate and effective.

The review may consider:

Reported incidents and concerns.
Changes in services, customers or suppliers.
The effectiveness of financial and approval controls.
Feedback from employees and associated persons.
Changes in applicable law or official guidance.
The need for additional training or revised procedures.

This policy will be reviewed at least annually and sooner if significant changes or incidents make an earlier review appropriate.

19. Breaches and Consequences

Any breach of this policy will be treated seriously.

Depending on the circumstances, action may include:

Formal warnings or disciplinary action, up to and including dismissal where lawful and appropriate.
Termination or suspension of a supplier, subcontractor or other business relationship.
Recovery of losses or other contractual remedies where available.
Additional training, control improvements or other corrective measures.
Reporting the matter to the police or another relevant authority where appropriate.

Bribery may also result in criminal prosecution, fines, imprisonment or other legal consequences for individuals and, where the law provides, organisations.

No employee or associated person will be excused for bribery because it was intended to benefit the Company, was requested by a customer or superior, or was considered customary in a particular business setting.

20. Policy Approval and Acknowledgement

This policy is adopted by Be Clean Services Limited as its formal Anti-Bribery & Anti-Corruption Policy.

The Company expects all relevant persons to comply with its requirements and to raise concerns about suspected wrongdoing.

Approved by: Ludiata Wasansua
Position: Director, Be Clean Services Limited

Signature: ______________________________________

Date of approval: ________________________________

Employee / Associated Person Acknowledgement

I confirm that I have received and read the Be Clean Services Limited Anti-Bribery & Anti-Corruption Policy. I understand my responsibility to comply with its requirements and to report suspected bribery or corruption.

Name: __________________________________________

Position / Company: ______________________________

Signature: ______________________________________

Date: ___________________________________________

Reference Legislation and Guidance

Bribery Act 2010.
UK Ministry of Justice, Bribery Act 2010: Guidance about procedures which relevant commercial organisations can put in place to prevent persons associated with them from bribing.
Applicable employment, whistleblowing, accounting and data protection requirements.

This policy should be read alongside any relevant Company procedures for procurement, expenses, financial controls, complaints and whistleblowing.

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