1. Policy Statement

Business Together Limited (company registration number 9593738), trading as BTLITC, operates a zero-tolerance approach to bribery and corruption in all forms. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems to counter bribery.

This policy applies to all individuals working at all levels and grades for BTLITC, including directors, employees, contractors, consultants, agents, and any other persons associated with us, wherever located.

2. What Is Bribery?

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action that is illegal, unethical, or a breach of trust. An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract, or any other benefit.

It is an offence under the UK Bribery Act 2010 to:

offer, promise, or give a bribe
request, agree to receive, or accept a bribe
bribe a foreign public official

The Act also creates a strict liability corporate offence for organisations that fail to prevent bribery by associated persons. BTLITC takes this obligation seriously and maintains proportionate procedures to address the risk.

3. Gifts and Hospitality

BTLITC recognises that giving and receiving gifts and hospitality is a normal part of building business relationships. However, these must never be used as a substitute for proper business engagement, nor offered or accepted where they could influence or be seen to influence a business decision.

Acceptable gifts and hospitality must be:

of modest and proportionate value
in line with normal business practice in the relevant sector
recorded in the gifts and hospitality register
approved by a director where the value exceeds £50

Cash gifts, gifts of significant monetary value, and any hospitality offered to or by a public official require prior written approval from a director.

4. Facilitation Payments

BTLITC does not make, and will not accept, facilitation payments. These are unofficial payments made to public officials to speed up routine government actions, regardless of how small the amount or how common the practice in a given country. Such payments are prohibited under this policy and under the UK Bribery Act 2010.

5. Third-Party Due Diligence

We carry out due diligence on third parties (including agents, intermediaries, sub-contractors, and joint venture partners) before engaging them. The level of due diligence is proportionate to the risk presented by the relationship and the jurisdiction involved.

We will not engage any third party where there are reasonable grounds to believe they may engage in bribery or corrupt conduct on our behalf.

6. Responsibilities

All persons associated with BTLITC must:

read, understand, and comply with this policy
raise concerns promptly if they believe or suspect a conflict with this policy has occurred or may occur
help identify bribery risks and assist in addressing them

Directors and managers must:

model appropriate conduct in all business dealings
ensure those reporting to them are aware of and comply with this policy
monitor compliance and respond promptly to any breaches

7. Reporting Concerns

Any suspicion or knowledge of bribery, corruption, or a breach of this policy must be reported immediately to the Managing Director or by email to [email protected].

BTLITC is committed to ensuring that individuals who raise concerns in good faith are not subject to any detriment or disadvantage as a result. Concerns raised in good faith will be treated confidentially wherever possible.

8. Record Keeping

BTLITC maintains clear and accurate records of all financial transactions and of gifts and hospitality received or given. All accounts, invoices, and other documents must be prepared with care and accuracy. False, misleading, or inaccurate record keeping will be treated as a serious disciplinary matter.

9. Consequences of Breach

Any employee who breaches this policy will face disciplinary action, which may include dismissal for gross misconduct. Associates, contractors, or agents found to be in breach may have their engagement terminated immediately.

In addition, breach of the UK Bribery Act 2010 carries personal liability of up to 10 years imprisonment and an unlimited fine for individuals, and an unlimited fine for organisations.

10. Review

This policy is reviewed annually by the Board of Directors. Any changes will be communicated to all relevant personnel. The policy may also be reviewed at any time following changes to applicable legislation or significant changes to our business activities.

11. Contact

Business Together Limited (trading as BTLITC)
Oak House, Central Park, Reeds Crescent, Watford, WD24 4QN
Email: [email protected]
Phone: +44 1923 751 624
Company Registration: 9593738 | VAT Number: 306383317

Anti-Bribery and Anti-Corruption Policy