Anti-Bribery and Corruption Statement

1. Introduction and Scope

Over the years, WISE Worksafe Ltd has implemented a variety of policies and procedures to guide employees and Board members in functioning efficiently, transparently, ethically, and sustainably. These systems are designed to ensure that officers of the company plan and deal with transactions for customers and potential customers in a transparent and consistent manner.

Anti-bribery and corruption form an integral control mechanism enshrined within the company’s operating plan and ethical business policies.

This document should be read in conjunction with our Corporate and Social Responsibility (CSR) Statement (which outlines our broader values) and our Ethical Policy & Accreditations (which details our operational standards).

This Statement applies to the Board, senior management, and all employees without favour. It applies equally to our interactions with customers, potential customers, suppliers, and potential suppliers.

2. Key Principles and Definitions

WISE Worksafe employees are expected to act with absolute honesty, integrity, fairness, and transparency at all times.

•Legal Compliance:

The company strictly adheres to the Bribery Act 2010, which states that companies and individuals can be prosecuted for both active bribery (offering a bribe) and passive bribery (requesting or accepting a bribe), carrying sentences of unlimited fines and potential imprisonment.

•Definition of Bribery:

Bribery is defined as offering, promising, or giving a financial or other inducement/reward to a person or company which may be improper, an abuse of power, or a misuse of corporate funds. It extends beyond the handling of cash to include gifts, hospitality, and entertainment that are non-educational, go beyond normal relationship building, and could be construed as intended to influence a decision or business transaction.

•Definition of Corruption:

Corruption is defined as any form of abuse of entrusted power for private gain.

•Our Stance:

Bribery and corruption are illegal, immoral, and damaging to the company's reputation. They contradict the stated Vision, Mission, and Values of WISE Worksafe and will not be tolerated in any form.

Note: Normal, proportionate hospitality and relationship building with customers, suppliers, and partners is not considered unsafe or prohibited.

3. Risk Assessment and Mitigation

WISE Worksafe does not believe that its core business activities possess a high inherent risk of corruption or acts of bribery, due to the following controls:

•Tender Controls:

Large contracts and business transactions are generally governed by formal tender processes and are subject to rigorous public sector anti-corruption procedures.

•Management Oversight:

Very large offers that are not bid through tenders involve multiple members of the senior management team, preventing unilateral deal-making.

•Standardised Pricing:

Where possible, we standardise pricing, which assists us in identifying unorthodox or unusual sales activity.

•Financial Monitoring:

Sales activity is monitored by internal accountants and the senior management team on a rolling basis.

4. Perceived Risk Areas

While our overall risk is low, we actively focus on the following potential risk areas with our employees:

•Gifts and Hospitality:

Excessive gifts, entertainment, and hospitality are prohibited. All such activities must fall within the company’s approved Corporate Policy.

•Facilitation Payments:

Fast-track or facilitation payments are strictly controlled. They are only permitted when legitimately necessary to expedite a service or supply, or because standard credit terms demand pre-payment, and must be fully documented.

•Reciprocal Agreements:

A ‘quid pro quo’ is not acceptable unless it represents a legitimate, open business arrangement that is properly documented and approved by senior management. Improper payments or discounts designed solely to secure business or a competitive advantage must not be accepted or made.

•Expenses:

The Bribery Act permits genuine acts of hospitality and related expenses. However, employees are not permitted cash in advance. Employees must advance reasons for claimed expenses, justify decision-making, provide proof of expenditure, and reclaim expenses strictly within the business Corporate Policy.

•Charitable Donations:

Charitable donations are permitted and encouraged as part of our CSR commitment, but only for registered charities and causes not linked to employees and never made in order to gain a commercial advantage.

5. Responsibilities and Reporting

•Leadership:

The Managing Director is responsible for overseeing the implementation of this Statement. Managers are responsible for its implementation across service lines and the procurement of goods and services.

•Employees:

All employees are responsible for following the letter and spirit of this Statement. WISE Worksafe management will always be available to advise an employee about a particular concern related to full compliance with the Bribery Act.

•Reporting:

The prevention, detection, and reporting of bribery or corruption is the responsibility of everyone throughout the company. Any member of staff who experiences, directly or indirectly, assumed bribery or corruption, or has legitimate business concerns, has a duty to report it openly, directly, and without delay to a manager.

•Investigation:

Such reports will be treated confidentially and robustly investigated by an independent party. Any issues will be recorded by senior management as appropriate.

Any member of staff found to solicit, extract, coerce, or gain benefit from bribery or corruption will be subject to disciplinary action, which could result in summary dismissal.

WISE Worksafe Ltd

Last Reviewed: 6 April 2026