Bribery Act 2010 Policy for Soul Spaces

1. Introduction

Soul Spaces is committed to conducting business with the highest ethical standards and integrity. We have a zero-tolerance approach to bribery and corruption in all its forms. This policy outlines our commitment to complying with the UK Bribery Act 2010 and promoting a culture of transparency and ethical conduct throughout our business operations.

2. Scope

This policy applies to all employees, directors, officers, consultants, contractors, agents, and any other individuals or entities acting on behalf of Soul Spaces. It covers all our business activities, including but not limited to:

• Finding and securing office spaces: Identifying suitable properties, negotiating leases, and managing property transactions.
• Design and build: Engaging architects, designers, and construction companies for office design and build projects.
• Procurement: Sourcing furniture, fixtures, equipment, and other materials from suppliers.
• Interactions with public officials: Obtaining permits, licenses, and approvals from government agencies.

3. Policy Statement

Soul Spaces prohibits the offering, giving, receiving, or soliciting of any bribe, whether directly or indirectly, to or from any person or entity, for any purpose. This includes:

• Bribery of public officials: Offering or giving any financial or other advantage to a public official to influence their decision-making or secure an improper advantage.
• Commercial bribery: Offering or giving any financial or other advantage to a private individual or entity to gain a business advantage or influence their decision-making.
• Facilitation payments: Offering or giving small payments to expedite routine government actions or services.

4. Key Principles

• Proportionality: Gifts and hospitality must be proportionate and reasonable in value, and must not be given with the intention of influencing a business decision.
• Transparency: All gifts, hospitality, and expenses must be accurately recorded and reported in accordance with our internal procedures.
• Due diligence: We will conduct due diligence on our business partners, including suppliers and agents, to assess their compliance with anti-bribery laws and regulations.
• Confidentiality: We will treat all reports of bribery and corruption with confidentiality and protect individuals who raise concerns in good faith.

5. Gifts and Hospitality

Soul Spaces recognizes that gifts and hospitality may be offered or received in the normal course of business. However, these must always comply with the following guidelines:

• No expectation of reciprocity: Gifts and hospitality should not be offered or accepted with the expectation of receiving something in return.
• Reasonable and proportionate: Gifts and hospitality should be of a reasonable and proportionate value, considering the nature of the relationship and the circumstances.
• Transparent and recorded: All gifts and hospitality must be accurately recorded and reported in accordance with our internal procedures.
• No cash or cash equivalents: Cash or cash equivalents should never be offered or accepted as gifts.

6. Facilitation Payments

Soul Spaces strictly prohibits the offering or making of facilitation payments. These are small payments made to expedite routine government actions or services. While these payments may be common in some countries, they are considered a form of bribery under the UK Bribery Act.

7. Training and Awareness

Soul Spaces will provide regular training and awareness programs to all employees on the Bribery Act and this policy. This training will cover:

• The key provisions of the Bribery Act.
• The risks and consequences of bribery and corruption.
• Our internal procedures for reporting concerns.
• How to identify and avoid potentially bribery situations.

8. Whistleblowing

Soul Spaces encourages all employees and stakeholders to report any concerns or suspicions of bribery or corruption. We have a confidential whistleblowing procedure in place to protect individuals who raise concerns in good faith. This can be done through a dedicated hotline, email address, or online reporting platform.

9. Monitoring and Review

This policy will be reviewed and updated regularly to ensure it remains effective and compliant with the latest legal and regulatory requirements. We will monitor its implementation through regular audits, risk assessments, and employee feedback.

10. Consequences of Non-Compliance

Any breach of this policy will be taken seriously and may result in disciplinary action, up to and including termination ¹ of employment. We may also report any suspected criminal activity to the relevant authorities.

11. Responsibility

The Operations Manager has overall responsibility for the implementation and enforcement of this policy. All employees are responsible for complying with this policy and reporting any concerns.

Approved by: This statement has been approved by the organisation’s board of directors, who will review and update it annually.

Date: January 1st, 2025