Anti-Bribery Policy

Introduction

Baker Stuart is committed to operating responsibly and fairly. The Company has a zerotolerance approach to bribery and corruption. Maintaining lawful and ethical practices is essential to protecting our reputation and building trust with clients, suppliers and partners.

This policy sets out how we meet our obligations under the Bribery Act 2010 in the UK and in any other country where we work.

Purpose and Scope

The aims of this policy are to:

Ensure compliance with anti-bribery laws and guidance
Help employees and associated persons recognise and prevent bribery
Provide clear routes for raising concerns
Maintain an ethical, open and responsible culture

This policy applies to all employees, contractors, consultants, agency staff, directors, suppliers and anyone acting on behalf of Baker Stuart (“associated persons”).

All are responsible for preventing, detecting and reporting bribery or suspected bribery.

Legal Obligations

Under the Bribery Act 2010 it is an offence to:

Offer, promise or give a bribe
Request, agree to receive or accept a bribe
Bribe a foreign public official
Fail to prevent bribery by associated persons

Both individuals and the Company can face criminal sanctions, including unlimited fines and reputational damage.

A bribe is any financial or other advantage offered to gain a commercial, contractual, regulatory or personal benefit.

Policy Requirements

All employees and associated persons must:

Act honestly and with integrity
Comply with anti-bribery laws
Uphold the Company’s values and ethical standards
Never offer or accept bribes or facilitation payments
Never create or use accounts or funds intended for improper payments

If unsure whether something may breach this policy, speak to your line manager or the Operations Manager (the Company’s Anti-Corruption Officer).

Gifts and Hospitality

Reasonable and proportionate hospitality or business gifts may be offered or accepted as part of building professional relationships. They must never be used to influence business decisions’.

Gifts or hospitality must meet the following rules:

They must be lawful
They must be appropriate in type and value
They must be given or received openly, not secretly
They must never include cash or cash equivalents
They must not be offered to obtain or retain business or secure an improper advantage
They must be provided in the Company’s name, not a personal name
They must be approved in advance by a Director if they may be considered unusual, sensitive or high-value

Any gift or hospitality that could be seen as excessive or intended to influence a decision must be declined.

Facilitation Payments

Facilitation payments (small payments to speed up routine actions) are strictly prohibited, even in countries where this may be common practice.

Reporting Concerns

Employees and associated persons must report any concerns or suspicions of bribery at the earliest opportunity. This includes concerns about their own actions.
Reports should be made through the Company’s Whistleblowing (Public Interest Disclosure) Policy.

While we cannot offer a fully anonymous internal mechanism due to our size, concerns will be handled sensitively and confidentially wherever possible. Reports made in good faith will never result in detrimental treatment.

Possible signs to report include:

Requests for unusual fees
Refusal to issue invoices or receipts
Excessive or lavish gifts or hospitality
Cash-only requests
Suspicious or unclear charging arrangements

Responsibilities

All employees and associated persons must take reasonable steps to prevent, detect and report bribery.

Directors and senior management are responsible for:

Setting the tone for ethical behaviour
Ensuring adequate procedures are in place
Supporting investigations and corrective action

The Anti-Corruption Officer oversees compliance and reviews the effectiveness of this policy.

Due Diligence

Before entering into agreements with suppliers, agents or consultants, reasonable checks must be carried out in line with the Company’s procurement and risk processes.

This includes ensuring that third parties understand and agree to follow this policy.

Record Keeping

Accurate records must be kept for:

Contracts and commercial arrangements
Invoices and payment transactions
Engagement of agents or third parties

No off-record or unapproved accounts may be created.

The Company conducts periodic reviews of financial controls and anti-bribery processes to ensure they remain effective.

Training and Awareness

Training is provided at induction and refreshed regularly.

Contractors and consultants may receive training where proportionate to the level of risk.

The Company’s zero-tolerance approach to bribery will be communicated to partners and suppliers at the start of any relationship.

Sanctions for breach

Breaching this policy is a disciplinary offence. Serious breaches may amount to gross misconduct and result in dismissal.

For associated persons or suppliers, breaches may lead to termination of contracts.

Where criminal activity is suspected, the Company may report the matter to the police or relevant authorities.

Data Protection

Any personal information processed under this policy will be handled in line with the Company’s Data Protection Policy and internal privacy notices. Improper access or disclosure may lead to action under the disciplinary procedure

Monitoring and Review

The Anti-Corruption Officer is responsible for reviewing this policy regularly and reporting to the Directors.

This policy is kept under continual review to ensure compliance with legal and ethical standards

This Policy Statement has been approved and authorised by:

Name: Wayne Spiller

Position: Managing Director

Date: 17th December 2025

Signature: