C WRAY LTD – ANTI-BRIBERY & CORRUPTION POLICY

Effective Date: 01/04/2026
Version: 1.0

C Wray Ltd is committed to conducting business with integrity, transparency, and accountability. We operate a zero-tolerance approach to bribery and corruption in all forms and are committed to complying with the UK Bribery Act 2010.

This policy applies to all employees, directors, operatives, subcontractors, and any third parties acting on behalf of C Wray Ltd.

Our Position

C Wray Ltd strictly prohibits:

  • Offering, giving, or promising any form of bribe or inducement

  • Requesting or accepting bribes, kickbacks, or improper payments

  • Making facilitation payments to secure or speed up services

  • Providing gifts or hospitality intended to improperly influence business decisions

Acceptable Business Practices

Reasonable and proportionate hospitality or promotional activity may be permitted where it:

  • Is not intended to influence a business decision improperly

  • Is transparent and openly recorded

  • Complies with applicable laws and client policies

Responsibilities

All individuals associated with C Wray Ltd must:

  • Act honestly and with integrity at all times

  • Avoid situations that could give rise to bribery or corruption risks

  • Report any suspected or actual instances of bribery immediately

  • Comply with this policy and relevant legislation

Risk Areas (Relevant to Our Business)

As a labour supply agency, key risk areas include:

  • Supplier or subcontractor selection

  • Referral or introducer arrangements

  • Gifts or incentives offered to secure contracts

  • Payments linked to securing work or preferential treatment

C Wray Ltd will ensure all commercial arrangements are transparent and properly documented.

Reporting Concerns

Any concerns regarding bribery or corruption must be reported to management immediately.

All reports will be:

  • Treated confidentially

  • Investigated promptly

  • Addressed appropriately

No individual will suffer any detriment for raising genuine concerns in good faith.

Monitoring & Compliance

C Wray Ltd will:

  • Review this policy periodically

  • Maintain clear records of business transactions

  • Ensure transparency in all financial dealings

  • Take disciplinary action where breaches occur

Breaches

Any breach of this policy may result in:

  • Termination of contracts or employment

  • Removal from the company’s worker database

  • Legal action where appropriate

Responsibility

The Director of C Wray Ltd is responsible for implementing and enforcing this policy and ensuring compliance across all operations.

Signed:
 Jovid Cain
Director, C Wray Ltd