Anti-Bribery & Corruption Statement

Bright Lambs Ltd is committed to conducting all of our business honestly, fairly and with integrity. We have a zero-tolerance approach to bribery and corruption and we expect the same standards from everyone we work with.

This statement sets out our high-level commitment. It sits alongside our internal policies and procedures, which provide more detailed guidance for our directors, employees and contractors.

Scope

This statement applies to:

• Directors and employees of Bright Lambs Ltd
• Contractors and associates working on our behalf
• Any third parties representing us (for example, consultants, subcontractors or introducers)

We also expect our suppliers and partners to uphold standards that are consistent with this statement.

What we mean by bribery and corruption

For the purposes of this statement, bribery includes any offer, promise, giving, request or acceptance of an undue financial or other advantage with the intention of:

• Influencing someone’s actions or decisions; or
• Securing an improper business advantage.

Corruption is the abuse of entrusted power for private gain.

This includes (but is not limited to):

• Cash payments or “kickbacks”
• Secret commissions or referral fees
• Inappropriate gifts, hospitality or entertainment
• Offering or accepting anything of value to bias our recommendations or advice

Our work as independent consultants

As business analysis and digital transformation consultants, our clients trust us to provide independent, objective advice.

In practical terms, this means:

• We do not accept incentives from software vendors, implementation partners or other suppliers in exchange for favourable treatment or recommendations.
• We base our advice and recommendations on our professional judgement, evidence and our clients’ best interests – not on any personal benefit.
• If we have any potential conflict of interest (for example, prior relationships with suppliers), we will declare this to the client and manage it transparently.

Gifts, hospitality and benefits

We recognise that modest, proportionate business hospitality can be a normal part of doing business. However:

• Any gifts or hospitality must be reasonable, infrequent and clearly not intended to influence a business decision.
• We do not offer or accept gifts, hospitality or other benefits that could create a sense of obligation or compromise our independence.
• Cash or cash-equivalent gifts (such as vouchers) are never acceptable.
• Where there is any doubt, we will err on the side of caution and decline.

Public officials and tender processes

We will not:

• Offer, promise or give anything of value to public officials, or to staff of public bodies or regulated entities, with the intention of securing an improper advantage; or
• Attempt to improperly influence tender processes, procurement decisions or regulatory outcomes on behalf of our clients.

Where we support clients through procurement or tendering, we will encourage transparent, fair and compliant processes.

Facilitation payments and “unofficial” fees

We do not make facilitation payments (small, unofficial payments made to speed up routine actions) and we do not permit anyone acting on our behalf to do so.

If we were ever placed under pressure to make such a payment, we would refuse and, where appropriate, record and escalate the incident.

Speaking up and reporting concerns

We encourage anyone working with or for Bright Lambs to raise concerns if they suspect bribery, corruption or behaviour that falls short of this statement.

Concerns can be raised directly with a director or via:
concerns@brightlambs.co.uk (marked “Confidential – Ethics”)

We will take concerns seriously, handle them sensitively, and will not tolerate victimisation of anyone who raises an issue in good faith.

Consequences of breaches

Any breach of this statement or our internal anti-bribery and corruption policies may result in:

• Disciplinary action for employees or contractors (up to and including termination of engagement)
• Ending relationships with third parties who act on our behalf
• Reporting serious matters to the relevant authorities where required

Our ongoing commitment

We are committed to:

• Reviewing this statement and our internal policies periodically
• Raising awareness among our team about bribery, corruption and conflicts of interest
• Continually improving our approach as our business grows

Our aim is to build long-term, trusted relationships with clients, partners and suppliers based on honesty, transparency and integrity.