Anti-Slavery and Anti-Bribery & Corruption Policies

COLABR8 Anti-Slavery and Anti-Bribery & Corruption Policies

Part A: Anti-Slavery and Human Trafficking Policy

A1. Policy statement

COLABR8 Limited (SC651494) has zero tolerance of modern slavery and human trafficking in any form, in its own business or its supply chains. We will act ethically and with integrity in all our business relationships, and put in place effective controls to make sure slavery and trafficking are not taking place anywhere we have influence.

This policy is approved by the Board and is reviewed at least once a year.

A2. Scope

This policy applies to everyone who works for or with COLABR8, including directors, employees, agency and temporary workers, contractors, sub-contractors, installers, sales agents, introducers and consultants ("Workers").

We expect our suppliers, distributors and partners to hold the same standards, and we will tell them so.

This policy does not form part of any employee's contract of employment, and we may amend it at any time.

A3. What modern slavery is

Modern slavery is a crime and a violation of human rights. It includes:

• Slavery, servitude and forced or compulsory labour: making someone work through threats, force, debt, or holding their documents;
• Human trafficking: arranging or helping someone to travel so that they can be exploited;
• Debt bondage: making someone work to pay off a debt they can never realistically clear;
• Child labour: work that harms a child or keeps them from education.

In Scotland these offences are set out in the Human Trafficking and Exploitation (Scotland) Act 2015. The Modern Slavery Act 2015 applies across the UK, including the supply chain transparency duty in section 54.

A4. Where the risks are in our business

COLABR8 is a broker and reseller of telecoms, energy and security services. Most of our direct risk is low, but our supply chains include higher-risk areas:

A5. Due diligence

To manage these risks, COLABR8 will:

• keep a list of our main suppliers and sub-contractors, rated by the risk levels above;
• ask new medium- and high-risk suppliers to confirm in writing that they comply with the Modern Slavery Act 2015 and this policy, and to share their own slavery statement or policy;
• include anti-slavery clauses in our sub-contractor and supplier terms, giving us the right to audit and to end the contract for breach;
• prefer hardware brands and distributors that publish a modern slavery statement and supply chain audits;
• check that installation sub-contractors pay at least the National Minimum Wage, carry out right-to-work checks, and do not charge workers recruitment fees;
• act on any credible report of exploitation, including by pausing work with the supplier while we investigate;
• work with a supplier to fix a problem where possible, and end the relationship where it will not change.

We will record our checks and review the supplier list at least once a year.

A6. Recruitment and our own people

COLABR8 will:

• carry out right-to-work checks on every employee before they start, and keep copies;
• pay at least the National Minimum or Living Wage, and give every employee a written statement of terms;
• never hold a Worker's passport, ID or other personal documents;
• never charge Workers fees for recruitment, training or equipment;
• use only reputable recruitment agencies that confirm they meet the same standards.

A7. Responsibilities and reporting concerns

The Board has overall responsibility for this policy. The Compliance Officer, [name, role], is responsible for day-to-day compliance, supplier checks and training.

Every Worker must read and follow this policy. If you believe or suspect that slavery or trafficking is taking place in our business or supply chain, you must report it straight away to the Compliance Officer or a director. You do not need proof.

If someone is in immediate danger, call 999. You can also report concerns, anonymously if needed, to the Modern Slavery & Exploitation Helpline on 08000 121 700 or to Police Scotland on 101.

Concerns can also be raised under COLABR8's Whistleblowing Policy. No one will suffer any detriment for raising a genuine concern in good faith, even if it turns out to be mistaken.

A8. Training, breaches and review

Staff who deal with suppliers, sub-contractors or recruitment will receive training on spotting and reporting the signs of modern slavery, on induction and every year.

Any employee who breaches this policy will face disciplinary action, which may lead to dismissal for gross misconduct. We may end our relationship with any supplier or contractor that breaches it.

This policy will be reviewed by [date] and at least once a year after that.

Part B: Anti-Bribery and Corruption Policy

B1. Policy statement

COLABR8 Limited has zero tolerance of bribery and corruption. We win business on the quality of our advice, service and pricing, never through improper payments or favours. This applies to our dealings with customers, suppliers, distributors, landlords, public bodies and anyone else.

This policy sets out the "adequate procedures" COLABR8 has in place to prevent bribery, as the Bribery Act 2010 requires. It is approved by the Board and reviewed at least once a year.

B2. Scope

This policy applies to everyone who works for or on behalf of COLABR8, including directors, employees, agency workers, contractors, sales agents, introducers, sub-agents and consultants ("Associated Persons"), wherever they are.

It does not form part of any employee's contract of employment, and we may amend it at any time.

B3. What the law says

Under the Bribery Act 2010, which applies across the UK including Scotland, it is a crime to:

• offer, promise or give a bribe (section 1);
• request, agree to receive or accept a bribe (section 2);
• bribe a foreign public official (section 6).

A company commits an offence under section 7 if a person associated with it bribes someone to win or keep business for it, unless the company can show it had adequate procedures to prevent this. Individuals face up to 10 years in prison and an unlimited fine. The company faces an unlimited fine and exclusion from public contracts.

A bribe is any financial or other advantage (cash, gifts, hospitality, jobs, favours, discounts, kickbacks, or commission) given or received to make someone act improperly, or to reward them for doing so.

Corruption is the abuse of entrusted power or position for private gain.

B4. Gifts and hospitality

Reasonable, proportionate gifts and hospitality to build relationships are allowed. They are never allowed where they could influence, or look like they influence, a business decision.

All gifts and hospitality must be given openly, not secretly, to the business rather than to a person's private address, and must never be given to a person's family on their behalf.

B5. Commissions and supplier incentives

COLABR8 is paid commission by suppliers and distributors, and this is lawful when it is transparent. To keep it that way:

• we recommend products and suppliers on what best fits the customer's needs, not on which pays us the most;
• we disclose our commission or uplift to customers where the law, a regulator or our terms require it (for example, energy broker costs, which suppliers must show to all business customers), and on request;
• we never pay, or offer to pay, part of our commission or any other reward to a customer's employee, facilities manager, landlord's agent or adviser to steer the contract to us. This is a secret commission and is a bribe;
• supplier incentives such as bonuses, SPIFFs, prize draws and incentive trips must be paid to COLABR8, not to individuals, and must be declared to a director and recorded.

B6. Introducers, agents and other third parties

We can be liable for bribes paid by people acting for us. Before appointing any introducer, sub-agent, reseller or referral partner, COLABR8 will:

• carry out proportionate checks on who they are, who owns them, and their reputation;
• agree a written contract that includes anti-bribery terms and our right to end it for breach;
• make sure any fee is reasonable for the work done, set in writing, invoiced, and paid to a business bank account in their name in the UK;
• never pay a fee in cash, to a third party, or to an offshore account;
• stop payments and investigate if we see red flags, such as requests for unusual payment routes, vague invoices, or refusals to agree anti-bribery terms.

B7. Facilitation payments

COLABR8 does not make facilitation payments, which are small unofficial payments to speed up a routine action (for example, paying an engineer or official cash to jump a queue). They are bribes under UK law. The only exception is where someone faces a threat to their life or safety; report any such payment to a director straight away.

B8. Donations and sponsorship

COLABR8 does not make political donations. Charitable donations and sponsorships must be approved by a director, made to a registered charity or genuine organisation, never be linked to winning business, and be recorded.

B9. Conflicts of interest

You must tell a director in writing about any personal interest that could affect, or look like it affects, your judgement. Examples: a family member working for a customer or supplier, a side business, or a financial interest in a supplier. The director will decide how to manage it and record the decision.

B10. Records, reporting and whistleblowing

Records. COLABR8 keeps accurate books and records of all payments, commissions, introducer fees, gifts and hospitality. No payment may be made off the books or described falsely on an invoice or expense claim. Expense claims must be supported by receipts.

Reporting. If you are offered a bribe, asked to pay one, or suspect bribery or corruption, report it as soon as possible to the Compliance Officer, [name, role], or a director. You can also use COLABR8's Whistleblowing Policy.

Protection. No one will suffer demotion, penalty or other detriment for refusing to pay or accept a bribe, or for reporting a genuine concern in good faith, even if they lose business for COLABR8 as a result.

B11. Training, breaches and review

All staff will receive anti-bribery training on induction and every year. Sales staff and anyone who deals with introducers will receive extra training on commissions and secret commissions.

Any employee who breaches this policy will face disciplinary action, which may lead to dismissal for gross misconduct. We may end our relationship with any Associated Person who breaches it, and will report criminal conduct to Police Scotland or the Serious Fraud Office where appropriate.

The Compliance Officer will review the Gifts & Hospitality Register every quarter, and the Board will review this policy by [date] and at least once a year after that.