Anti-bribery and Corruption Policy

PURPOSE

Regal Estate Agents (trading name of Regal Capital Group Ltd) is committed to conducting business with the highest standards of integrity, transparency, and ethical behaviour. We have zero tolerance for bribery and corruption in all forms and are dedicated to complying with all applicable anti-bribery and corruption laws, including the UK Bribery Act 2010. This policy establishes clear guidelines for all individuals associated with our organisation to ensure that our business practices remain ethical, lawful, and aligned with our core values of honesty and integrity.

SCOPE

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, property partners, and business associates. This policy extends to all business activities, transactions, and relationships, whether conducted in the UK or internationally, and covers all interactions with public officials, private sector clients, suppliers, and other stakeholders.

This policy does not form part of any employee’s contract of employment and we may amend it at any time to reflect changes in legislation, best practice, or business requirements.

DEFINITIONS

Bribery: The offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal, unethical, or a breach of trust. This includes both monetary and non-monetary benefits.

Corruption: The abuse of entrusted power for private gain, including the misuse of public or private office for personal benefit.

Facilitation Payments: Small payments made to secure or expedite routine government actions, such as processing permits or licences. These are prohibited under this policy regardless of local customs.

Public Official: Any person holding a legislative, administrative, or judicial office, including employees of government departments, state-owned enterprises, public international organisations, and political parties.

Kickback: A form of bribery where a portion of the contract value is returned to the payer as a reward for awarding the contract or providing favourable treatment.

POLICY STATEMENT

Zero Tolerance Commitment
Regal Estate Agents operates a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships. We will not engage in, facilitate, or tolerate any form of bribery or corruption, whether direct or indirect, and regardless of the value involved or local customs and practices.

Ethical Business Conduct
We believe that ethical business conduct is fundamental to our success and reputation. We are committed to:
– Conducting all business activities with honesty and integrity
– Competing fairly and transparently in all markets
– Building relationships based on trust and mutual respect
– Maintaining the highest standards of professional conduct
– Promoting a culture of ethical behaviour throughout our organisation

Legal Compliance
We comply with all applicable anti-bribery and corruption laws, including:
– The UK Bribery Act 2010
– The Proceeds of Crime Act 2002
– Money Laundering Regulations
– All relevant international anti-corruption legislation

PROHIBITED ACTIVITIES

The following activities are strictly prohibited under this policy:

Direct Bribery
– Offering, promising, or giving any financial or other advantage to any person to induce them to perform their functions improperly
– Requesting, agreeing to receive, or accepting any such advantage in return for performing our functions improperly

Indirect Bribery
– Using third parties, agents, or intermediaries to offer, promise, give, request, or accept bribes on our behalf
– Making payments or providing benefits through subsidiaries, joint ventures, or other business relationships to circumvent anti-bribery laws

Facilitation Payments
– Making small payments to public officials to secure or expedite routine government actions
– Any payments intended to influence the timing or outcome of routine administrative processes

Kickbacks and Secret Commissions
– Paying or receiving kickbacks in connection with the award of contracts or business opportunities
– Accepting or providing secret commissions or undisclosed benefits in business transactions

Political Contributions
– Making political contributions on behalf of the company without proper authorisation and transparency
– Using political contributions to gain improper business advantages

ACCEPTABLE BUSINESS PRACTICES

Reasonable Hospitality and Gifts
We recognise that reasonable and proportionate hospitality and gifts can be legitimate aspects of business relationships. Such activities are acceptable provided they:

– Are reasonable and proportionate in the circumstances
– Are transparent and properly recorded in our books and records
– Are not intended to influence business decisions improperly
– Comply with local laws and the recipient’s policies
– Would not embarrass the company if made public
– Are not offered or provided to public officials without proper approval

Guidelines for Acceptable Hospitality:
– Business meals and entertainment of reasonable value
– Promotional gifts of nominal value bearing company branding
– Attendance at industry conferences and seminars
– Cultural or sporting events where there is a clear business purpose

Charitable Donations and Sponsorship
We may make charitable donations and provide sponsorship as part of our corporate social responsibility activities, provided they:
– Are made to legitimate charitable organisations
– Are transparent and properly documented
– Are not used as a means of circumventing anti-bribery laws
– Are approved through appropriate internal procedures
– Do not create conflicts of interest or improper influence

RISK ASSESSMENT AND DUE DILIGENCE

Risk Assessment
We regularly assess bribery and corruption risks in our business activities, considering:
– Geographic risk factors and local corruption levels
– Sector-specific risks in the property industry
– Transaction-specific risks, particularly high-value deals
– Third-party relationship risks
– Public sector interaction risks

Due Diligence Procedures
We conduct appropriate due diligence on:
– New business partners, agents, and intermediaries
– Suppliers and contractors, particularly those in high-risk categories
– Joint venture partners and acquisition targets
– Any party involved in significant business transactions

Our due diligence procedures include:
– Background checks and reputation assessments
– Review of anti-bribery policies and procedures
– Assessment of compliance culture and training
– Ongoing monitoring of business relationships
– Regular review and updating of due diligence information

THIRD-PARTY RELATIONSHIPS

Agent and Intermediary Management
When working with agents, consultants, or other intermediaries, we:
– Conduct thorough due diligence before engagement
– Include specific anti-bribery clauses in all agreements
– Ensure compensation is reasonable and commensurate with services provided
– Monitor their activities and conduct regular reviews
– Provide appropriate training and guidance on our policies
– Maintain the right to audit their compliance with our standards

Supplier and Contractor Requirements
We expect all suppliers and contractors to:
– Comply with all applicable anti-bribery and corruption laws
– Implement their own anti-bribery policies and procedures
– Provide training to their employees on bribery and corruption issues
– Report any suspected bribery or corruption to us immediately
– Allow us to audit their compliance with our requirements

Joint Ventures and Partnerships
For joint ventures and partnerships, we:
– Conduct enhanced due diligence on potential partners
– Ensure anti-bribery provisions are included in all agreements
– Establish clear governance and oversight mechanisms
– Provide regular training and communication on our policies
– Monitor compliance throughout the relationship

EMPLOYEE RESPONSIBILITIES AND TRAINING

Employee Responsibilities
All employees must:
– Comply with this policy and all applicable laws
– Report any suspected bribery or corruption immediately
– Complete mandatory anti-bribery training
– Declare any conflicts of interest or potential conflicts
– Seek guidance when uncertain about appropriate conduct
– Cooperate fully with any investigations or audits

Training and Awareness
We provide comprehensive anti-bribery training that includes:
– Understanding of legal requirements and company policies
– Recognition of bribery and corruption risks
– Practical guidance on acceptable business practices
– Reporting procedures and whistleblowing protections
– Case studies and scenarios relevant to our business
– Regular updates on legal and regulatory developments

Training is provided to:
– All new employees as part of their induction
– Existing employees on an annual basis
– High-risk roles and senior management more frequently
– Third parties and business partners as appropriate

REPORTING AND WHISTLEBLOWING

Reporting Obligations
We encourage and expect all employees, business partners, and stakeholders to report any concerns about bribery or corruption. Reports should be made immediately through any of the following channels:

– Direct reporting to line management or senior management
– Confidential reporting to our designated compliance officer
– Anonymous reporting through our whistleblowing hotline
– External reporting to relevant regulatory authorities

Whistleblowing Protection
We are committed to protecting those who report concerns in good faith by:
– Maintaining confidentiality where possible and appropriate
– Investigating all reports thoroughly and promptly
– Taking appropriate action based on investigation findings
– Protecting reporters from retaliation or adverse treatment
– Providing feedback on investigation outcomes where appropriate

Investigation Procedures
All reports of suspected bribery or corruption will be:
– Acknowledged promptly and treated seriously
– Investigated thoroughly by appropriately trained personnel
– Documented comprehensively with all evidence preserved
– Reported to relevant authorities where required by law
– Followed up with appropriate disciplinary or corrective action

MONITORING AND COMPLIANCE

Internal Controls
We maintain robust internal controls to prevent and detect bribery and corruption, including:
– Segregation of duties in financial processes
– Regular internal audits and compliance reviews
– Expense monitoring and approval procedures
– Gift and hospitality registers
– Conflict of interest declarations
– Regular risk assessments and control testing

Record Keeping
We maintain accurate and complete records of:
– All business transactions and financial dealings
– Gifts, hospitality, and entertainment provided or received
– Due diligence conducted on third parties
– Training provided to employees and business partners
– Reports of suspected bribery or corruption and investigations conducted

Compliance Monitoring
We regularly monitor compliance with this policy through:
– Internal audits and compliance reviews
– Employee surveys and feedback
– Third-party assessments and certifications
– Regular reporting to senior management
– Benchmarking against industry best practices

CONSEQUENCES OF NON-COMPLIANCE

Disciplinary Action
Violations of this policy may result in:
– Formal disciplinary action up to and including dismissal
– Termination of business relationships with third parties
– Recovery of any financial losses incurred
– Reporting to relevant professional bodies
– Cooperation with law enforcement investigations

Legal Consequences
Bribery and corruption are serious criminal offences that can result in:
– Unlimited fines for the company
– Personal criminal liability for individuals
– Imprisonment for up to 10 years
– Disqualification from holding company directorships
– Exclusion from public sector contracts
– Serious damage to reputation and business relationships

GOVERNANCE AND OVERSIGHT

Senior Management Responsibility
Our senior management team has overall responsibility for:
– Setting the tone and culture for ethical business conduct
– Ensuring adequate resources are allocated to anti-bribery efforts
– Overseeing the implementation and effectiveness of this policy
– Monitoring compliance and addressing any deficiencies
– Reporting to the board on anti-bribery matters
– Leading by example in all business dealings

Board Oversight
Our board of directors provides oversight of our anti-bribery programme by:
– Approving this policy and any significant changes
– Reviewing regular reports on compliance and effectiveness
– Ensuring adequate resources and support are provided
– Addressing any significant compliance failures
– Demonstrating commitment to ethical business conduct

POLICY REVIEW AND UPDATES

This policy will be reviewed annually by senior management to ensure it remains:
– Aligned with current legal and regulatory requirements
– Appropriate for our business activities and risk profile
– Effective in preventing bribery and corruption
– Consistent with industry best practices
– Clear and understandable for all stakeholders

Reviews will consider:
– Changes in applicable laws and regulations
– Developments in our business activities and relationships
– Lessons learned from compliance monitoring and investigations
– Feedback from employees and business partners
– External guidance and best practice recommendations

APPROVAL

This policy is approved by the senior management of Regal Estate Agents (trading name of Regal Capital Group Ltd) and demonstrates our commitment to conducting business with integrity and in compliance with all applicable laws.

CONTACT INFORMATION

For any questions about this policy, to report concerns, or to seek guidance on anti-bribery matters:

Regal Estate Agents (Trading name of Regal Capital Group Ltd)
Suite Ra01 195-197 Wood Street, London, E17 3NU
Email: contact@regalestateagents.co.uk
Phone: 01270 295673

EXTERNAL RESOURCES

Serious Fraud Office: sfo.gov.uk
National Crime Agency: nationalcrimeagency.gov.uk
Transparency International UK: transparency.org.uk
Government guidance on Bribery Act 2010: gov.uk/government/publications/bribery-act-2010-guidance