Anti-Bribery & Fraud Policy

Bribery & Fraud Policy Statement

Last Reviewed: 03/01/2025

Next Review Date: 03/01/2028

Highway Data Systems Ltd is committed to conducting business with integrity, transparency, and accountability. In compliance with the Bribery Act 2010, the Company operates a zero-tolerance approach to bribery and fraud. This applies to all employees, contractors, consultants, suppliers, and any third party acting on the Company’s behalf. 

Definitions

Bribery
Bribery includes offering, giving, requesting, or receiving any financial or other advantage with the intention of influencing the improper performance of a function or activity. This includes any inducement intended to influence decisions outside a fair and transparent process.

Fraud
Fraud includes any act of deception, dishonesty, or false representation intended to secure an unfair, unlawful, or unethical gain.

Management Responsibilities

Senior management has overall responsibility for ensuring compliance with this policy and for managing bribery and corruption risk within the business.

 Management is responsible for:

• Considering bribery and corruption risks proportionately as part of management oversight 

• Monitoring adherence to this policy through management oversight and established company procedures.

• Ensuring the policy is communicated at induction and reinforced through annual impartiality and confidentiality declarations.

• Investigating any suspected or reported incidents of bribery or fraud promptly, fairly, and as confidentially as reasonably possible. 

• Taking appropriate action, including disciplinary action, where breaches are identified.

• Supporting and protecting people who raise concerns, in accordance with the Company’s Whistleblowing Policy. 

Employee Responsibilities

All employees must:

• Act honestly, ethically, and in full compliance with this policy.

• Avoid any activity that could be perceived as bribery or fraud.

• Report suspected bribery or fraud as soon as reasonably practicable to your line manager, an uninvolved Company Director, or through the alternative reporting arrangements in the Company’s Whistleblowing Policy. 

• Complete impartiality and confidentiality declarations at induction and annually thereafter.

HDS will not tolerate retaliation or detrimental treatment against anyone who raises a concern on reasonable grounds or makes a protected disclosure, even where the concern is not substantiated. Nothing in this policy or any impartiality or confidentiality declaration restricts protected disclosures, obtaining confidential legal advice or other lawful reporting to external authorities. 

Gifts & Hospitality

Any gift or hospitality given or received with a value exceeding £50 must be recorded in the Company’s Gifts & Hospitality Register.

All gifts and hospitality must be reasonable, lawful, and transparent, and must never influence — or appear to influence — a business decision.

Monitoring & Enforcement

Compliance with this policy is monitored through:

• Ongoing management oversight

• Review of impartiality and confidentiality declarations

• Internal reporting and disciplinary processes
  
  

Alleged breaches will be investigated fairly. Breaches by employees may result in disciplinary action under the Company’s Disciplinary Procedure, up to and including dismissal. Serious breaches may amount to gross misconduct. Action involving contractors or other third parties will follow the applicable contractual and legal arrangements. Matters may also be reported to external authorities where appropriate. 

Consequences of Non-Compliance

The Company will take firm action against any individual found to have committed or been involved in bribery or fraud. This may include:

• Disciplinary action

• Termination of employment or contract

• Reporting to law enforcement or regulatory bodies

Training & Awareness

Anti-bribery and anti-corruption expectations are communicated:

• At induction

• Through annual impartiality and confidentiality declarations

• Through ongoing reinforcement by management

A standalone training programme is not in place, but awareness is maintained through the Company’s policies and management oversight.