Anti-Bribery and Corruption Policy

1. Purpose

Same Day Courier 247 Ltd is committed to conducting business honestly, fairly and professionally. The Company has a zero-tolerance approach to bribery, corruption, kickbacks and other improper business practices.

This policy supports the Company's compliance with the Bribery Act 2010.

2. Scope

This policy applies to all:

• Directors and employees.
• Temporary and agency workers.
• Drivers and owner-drivers.
• Subcontractors and subcontracted hauliers.
• Consultants, agents and representatives.
• Any other person acting for or on behalf of the Company.

3. Prohibited conduct

No person acting for or on behalf of the Company may:

• Offer, promise or give a bribe or improper advantage.
• Request, agree to receive or accept a bribe.
• Make or accept a kickback or secret commission.
• Make a facilitation payment.
• Use a third party to make a payment that the Company would not make directly.
• Offer money, gifts or hospitality to improperly influence a decision.
• Falsify records or conceal the true purpose of a payment.

What may constitute a bribe

A bribe can include money, gifts, hospitality, discounts, commissions, employment opportunities, preferential treatment or any other benefit intended to influence someone improperly.

4. Gifts and hospitality

Reasonable and proportionate business hospitality may be accepted or provided where it:

• Has a genuine business purpose.
• Is lawful, modest and infrequent.
• Is not cash or a cash equivalent.
• Is not intended to influence a business decision.
• Is not offered during a tender or contract negotiation where it could create an improper impression.
• Can be openly disclosed.

Disclosure and approval

Any gift or hospitality that is more than nominal, unusual or potentially sensitive must be disclosed to and approved by a director.

5. Third parties and subcontractors

The Company will carry out proportionate checks before appointing subcontractors, agents or other business partners.

No person may appoint or pay a third party where there is a reasonable suspicion that the third party may use part of the payment for bribery or another improper purpose.

Relevant subcontractors and suppliers may be required to comply with this policy or equivalent anti-bribery standards.

6. Payments and records

All invoices, expenses, commissions and other payments must:

• Be accurate.
• Have a legitimate business purpose.
• Be properly authorised.
• Be recorded in the Company's accounting or operational records.

Prohibited records

Off-book accounts, false invoices and misleading expense descriptions are prohibited.

7. Reporting concerns

Any person who is offered a bribe, asked to make an improper payment or becomes aware of suspected bribery must report the matter promptly to a director or the Compliance Contact.

Concerns will be treated seriously and, so far as reasonably possible, confidentially. No person will be penalised for raising a genuine concern in good faith.

8. Breaches

A breach may result in disciplinary action, termination of a subcontract or commercial relationship, recovery of losses and referral to the appropriate authorities.

9. Responsibility and review

The directors are responsible for promoting this policy and ensuring that proportionate anti-bribery controls are maintained.

This policy will be reviewed at least annually and whenever there is a significant change in the Company's activities or risk profile.

Approval

This policy was approved on behalf of Same Day Courier 247 Ltd.