1. Purpose

Yellowcom is committed to operating with integrity, transparency, and accountability in all business dealings. This Anti-Bribery and Corruption Policy outlines our zero-tolerance stance on bribery and corruption, ensuring compliance with the UK Bribery Act 2010 and the Irish Criminal Justice (Corruption Offences) Act 2018.

This policy applies to all Yellowcom employees, directors, contractors, suppliers, partners, and any third parties acting on behalf of Yellowcom.

2. Scope

This policy applies across all regions where Yellowcom operates, including the UK and the Republic of Ireland. It covers:

• Business dealings with clients, suppliers, and partners

• Procurement and contracting processes

• Gifts, hospitality, and entertainment

• Facilitation payments

• Sponsorships and charitable contributions

• Interactions with public officials

3. Definitions

Bribery: Offering, promising, giving, accepting, or requesting anything of value to influence a person’s actions.

Corruption: Abuse of entrusted power for private gain, including fraud, embezzlement, nepotism, or undue influence.

4. Policy Statements

4.1 Bribery is Prohibited

Yellowcom strictly prohibits offering, giving, soliciting, or receiving bribes in any form. This includes cash, gifts, hospitality, discounts, favours, or any benefit intended to improperly influence a business decision or gain an unfair advantage.

4.2 Facilitation Payments

Facilitation payments (small, unofficial payments made to secure or expedite routine services) are strictly prohibited, regardless of local custom or expectation.

4.3 Gifts and Hospitality

Gifts or hospitality must be:

• Occasional and reasonable

• For a legitimate business purpose

• Not cash or cash equivalents

• Not intended to secure business advantage

Employees must report any gift or hospitality over £100 / €120 to their line manager and record it in the company’s gift register.

4.4 Public Officials

Special care must be taken when interacting with public officials. No payments or gifts may be offered to public officials that could be seen as an attempt to influence official duties.

5. Responsibilities

Employees:

• Must comply with this policy at all times.

• Must report any concerns or suspicions of bribery or corruption.

Management:

• Responsible for promoting a culture of integrity.

• Must ensure employees and partners understand their obligations.

• Must maintain accurate records of all transactions and contracts.

Partners and Suppliers:

• Must agree to uphold this policy as part of all contractual agreements with Yellowcom.

• May be required to complete a due diligence questionnaire or sign a declaration of compliance.

6. Reporting and Whistleblowing

Yellowcom encourages transparency and protects whistleblowers. Any suspected or actual breach should be reported via:

📧 compliance@yellowcom.co.uk

Yellowcom will investigate all reports promptly and confidentially. No employee will face retaliation for reporting concerns in good faith.

7. Record-Keeping and Audit

We maintain clear, accurate records of all transactions, including:

• Invoices and receipts

• Contractual agreements

• Gift and hospitality logs

• Due diligence checks

Regular audits are conducted to ensure compliance and identify any red flags.

8. Consequences of Non-Compliance

Breaches of this policy are considered serious misconduct and may result in:

• Disciplinary action (up to dismissal)

• Termination of contracts or partnerships

• Reporting to legal or regulatory authorities

9. Training and Communication

• All Yellowcom staff will receive annual training on anti-bribery and corruption.

• This policy will be available on the company intranet and included in staff onboarding packs.

• All partners and contractors must review and acknowledge the policy during onboarding or tender stages.

10. Review and Updates

This policy will be reviewed annually and updated as necessary to reflect legislative changes, operational risks, or industry best practices.

Approved by: Yellowcom Executive Team
Effective Date: 10 May 2025