Anti-Bribery and Corruption Policy

October 2026

1. Purpose

Richard Barber & Company is committed to conducting business honestly, fairly and with integrity. We operate a zero-tolerance approach to bribery and corruption and are committed to complying with the UK Bribery Act 2010.
This policy applies to all partners, employees and anyone acting on behalf of the company.

2. Our Policy

Richard Barber & Company prohibits:

• Offering, promising, giving, requesting or accepting bribes or improper payments.
• Offering gifts or hospitality intended to influence business decisions improperly.
• Making facilitation payments to secure services.
• Using third parties to carry out activities that would breach this policy.

All business decisions must be made fairly, transparently and in the best interests of the business and its clients.

3. Gifts and Hospitality

Reasonable and proportionate business hospitality and modest gifts may be accepted or offered where they are appropriate, lawful and not intended to influence business decisions.
Any gifts or hospitality that could create a conflict of interest or appear inappropriate must be reported to a partner.

4. Responsibilities

• All partners and employees are responsible for:
• Understanding and complying with this policy.
• Acting honestly and professionally in all business dealings.
• Reporting any suspected bribery, corruption or improper conduct.
• Avoiding situations that could create conflicts of interest.

5. Reporting Concerns

Any suspected bribery or corruption should be reported promptly to a partner of Richard Barber & Company.
All concerns will be taken seriously, treated confidentially where possible and investigated appropriately.
No employee will suffer retaliation for raising a genuine concern in good faith.

6. Breaches of Policy

Any breach of this policy may result in disciplinary action, including dismissal where appropriate.
Serious breaches may also be reported to the relevant authorities.

7. Review

This policy will be reviewed annually or sooner if there are significant changes to legislation or business operations.