Graystone Office Solutions

1. Policy Statement

Graystone Office Solutions is committed to conducting its business ethically, transparently, and in full compliance with all applicable laws and regulations. The Company adopts a zero-tolerance approach to bribery and corruption in any form.

This policy is established in accordance with the UK Bribery Act 2010 and applies to all employees, directors, officers, contractors, agents, consultants, suppliers, and any other persons acting on behalf of Graystone Office Solutions.

2. Purpose of the Policy

The purpose of this policy is to:

• Set out the responsibilities of Graystone Office Solutions and those working for it in observing and upholding anti-bribery and anti-corruption standards
• Provide guidance on recognising and dealing with bribery and corruption risks
• Protect the Company from legal, regulatory, and reputational harm

3. Scope

This policy applies to:

• All employees, whether permanent, temporary, or agency
• Directors and senior management
• Contractors, subcontractors, agents, intermediaries, and representatives
• Business partners and suppliers where relevant

The policy applies to all business activities carried out in the UK and internationally.

4. Definition of Bribery and Corruption

Bribery is the offering, promising, giving, requesting, or accepting of any financial or other advantage to induce or reward improper performance of a function or activity.

Corruption includes bribery and any other dishonest or unethical conduct designed to influence decision-making for personal or business gain.

Bribes may include, but are not limited to:

• Cash payments
• Gifts, hospitality, or entertainment
• Discounts or preferential treatment
• Political or charitable donations intended to influence decisions
• Kickbacks or facilitation payments

5. Prohibited Conduct

It is strictly prohibited to:

• Offer, promise, give, or accept a bribe in any form
• Make facilitation payments, regardless of value
• Use third parties to carry out actions that would be prohibited if done directly
• Influence NHS, public sector, or private procurement decisions improperly
• Accept gifts or hospitality that could compromise impartiality

No employee or representative should ever feel pressured to engage in bribery to secure or retain business.

6. Gifts and Hospitality

Reasonable, proportionate, and transparent gifts or hospitality may be permitted where they:

• Are infrequent and of low value
• Are not intended to influence business decisions
• Are compliant with NHS and public sector gift and hospitality rules
• Are properly recorded where required

Cash or cash-equivalent gifts are never permitted.

If there is any doubt, approval must be obtained from senior management before acceptance or offering.

7. Public Sector and NHS Engagement

Graystone Office Solutions recognises the heightened risk associated with public sector and NHS engagements. Employees must:

• Comply fully with NHS procurement, ethical, and conflicts-of-interest requirements
• Declare any personal or financial interests
• Avoid offering gifts or hospitality to NHS staff beyond what is expressly permitted

8. Third Parties and Due Diligence

The Company will conduct appropriate due diligence on third parties acting on its behalf. This includes:

• Suppliers
• Agents
• Consultants
• Intermediaries

Contracts may include anti-bribery clauses and termination rights in the event of non-compliance.

9. Responsibilities

Management

• Ensure this policy is implemented and enforced
• Promote a culture of ethical conduct
• Assess and manage bribery risks

Employees and Representatives

• Read, understand, and comply with this policy
• Report any suspected bribery or corruption
• Avoid situations that may give rise to conflicts of interest

10. Reporting Concerns (Whistleblowing)

Any concerns or suspicions of bribery or corruption must be reported promptly to senior management or the designated compliance contact.

Reports will be treated confidentially, and no individual will suffer retaliation for raising a genuine concern in good faith.

11. Record Keeping

Accurate and transparent records must be maintained for:

• Expenses
• Gifts and hospitality
• Payments to third parties

False, misleading, or incomplete records are strictly prohibited.

12. Breaches of the Policy

Breaches of this policy may result in:

• Disciplinary action, up to and including dismissal
• Termination of contracts
• Reporting to regulatory or law enforcement authorities

13. Training and Awareness

Graystone Office Solutions will ensure that employees are aware of this policy and understand their obligations. Additional training may be provided where risk exposure is higher.

14. Review and Monitoring

This policy will be reviewed periodically to ensure ongoing compliance with legal and regulatory requirements and to reflect changes in business operations.