Anti-Bribery and Corruption Policy

1. Our position

Vyce operates a zero-tolerance approach to bribery and corruption, and complies fully with the Bribery Act 2010.

Bribery is a criminal offence carrying up to 10 years' imprisonment for individuals, unlimited fines for individuals and companies, and exclusion from public sector contracts. Section 7 of the Act creates a corporate offence of failing to prevent bribery by an associated person, with a defence of having adequate procedures in place. This policy forms part of those procedures.

2. What's prohibited

• Offering, promising, giving or receiving a bribe to obtain a business advantage
• Facilitation payments
• Kickbacks
• Gifts or hospitality intended to influence a business decision
• Bribery of foreign public officials

3. Who this covers

Employees, contractors, consultants, interns, agents, suppliers, business partners, officers and Board members. We expect third parties working with us or on our behalf to meet the same standard.

4. Your responsibilities

• Never take part in bribery or corrupt activity
• Report any suspected bribery to hello@vyce.io
• Refuse any bribe or facilitation payment, and record the attempt
• Make sure third parties you deal with understand this policy

Failure to comply may result in disciplinary action, including dismissal, and legal consequences.

5. Gifts and hospitality

Reasonable, transparent and proportionate business hospitality is permitted.

Acceptable: given in the company's name rather than an individual's; lawful; not cash or cash equivalent including gift cards; openly declared and recorded; given without expectation of a favour; below £100 in value unless approved in advance; not offered to government officials or politicians without prior approval.

Not acceptable: anything intended to influence a decision unfairly; anything implying a return favour; cash or cash equivalents; lavish entertainment beyond reasonable business practice; undeclared gifts; anything given selectively to key decision-makers.

6. Facilitation payments and kickbacks

Both are prohibited. Report any demand for one immediately. If a payment becomes unavoidable because of a threat to personal safety, keep it to a minimum, get a receipt if you can, and report it as soon as you're safe.

7. Political and charitable contributions

We make no political donations in cash or in kind. Charitable contributions require approval, so they can't be used as cover for bribery.

8. Fraud

The Economic Crime and Corporate Transparency Act 2023 created a corporate offence of failing to prevent fraud, which applies to large organisations. Vyce is below those thresholds, but we apply the same principle: fraud committed by anyone associated with Vyce, intended to benefit Vyce, is prohibited and will be treated as seriously as bribery under this policy.

9. Reporting a concern

Email hello@vyce.io, or use our confidential reporting line on 0203 868 6303. We accept and investigate anonymous reports. Anyone reporting in good faith is protected from victimisation.

10. Records and review

Gifts, hospitality and relevant payments are recorded centrally. This policy is reviewed annually.