Anti-Corruption and Bribery Policy

Last modified: October 2024

At SPARK CPD LTD, we are committed to conducting our business with the highest ethical standards and in compliance with all applicable laws and regulations related to anti-corruption and anti-bribery. This policy is designed to ensure that SPARK CPD LTD maintains integrity and transparency in all its operations and business dealings.

1. Purpose of the Policy

The purpose of this Policy is to: prevent bribery and corruption in all business activities conducted by SPARK CPD LTD.

Set clear guidelines for identifying, reporting, and avoiding bribery and corrupt activities.

Ensure compliance with relevant anti-bribery and anti-corruption laws, including the UK Bribery Act 2010.

2. Definition of Bribery and Corruption

Bribery: Bribery refers to offering, promising, giving, or receiving something of value with the intent to influence the recipient's actions in favor of the giver, typically to gain an unfair advantage.

Corruption: Corruption refers to dishonest or fraudulent conduct by those in power, typically involving bribery, to gain personal or business advantage.

Examples of Bribery

Offering cash, gifts, or favors to influence a decision.

Accepting payments, gifts, or other incentives in return for favorable treatment or business.

3. Prohibited Conduct

The following activities are strictly prohibited for anyone acting on behalf of SPARK CPD LTD:

Offering, giving, promising, soliciting, or accepting any form of bribe, whether directly or through a third party.

Engaging in corrupt practices, including facilitating payments.

Offering or accepting anything of value to influence decisions related to CPD programs, partnerships, or certifications.

4. Gifts and Hospitality

While offering or receiving gifts and hospitality can be part of business culture, it must not be used to influence or attempt to influence any decisions. The following guidelines apply:

Gifts: Gifts of nominal value (e.g., branded items) are generally acceptable, provided they are given in good faith and do not influence business decisions.

Hospitality: Reasonable and proportionate hospitality (e.g., meals, events) is permissible, provided it is not used to obtain an unfair advantage.

5. Reporting and Whistleblowing

Employees, contractors, or third parties working with SPARK CPD LTD are required to report any suspected instances of bribery, corruption, or violations of this Policy. All reports will be treated confidentially, and the Company will protect individuals who report in good faith from retaliation.

Report suspected violations to:Email: aaddcpd@gmail.com,Telephone: 07421476747

6. Responsibilities

Leadership and Management: The senior management of SPARK CPD LTD is responsible for overseeing compliance with this Policy and ensuring that adequate training and awareness programs are provided.

7. Consequences of Non-Compliance

Non-compliance with this Policy may result in disciplinary action, legal consequences, or termination of employment or contracts.

8. Compliance with Laws

This Policy is designed to comply with applicable anti-corruption and anti-bribery laws, including the UK Bribery Act 2010. All employees and third parties are expected to follow the law and maintain high standards of ethical conduct.

9. Monitoring and Review

The Company will regularly review this Policy to ensure it remains effective, up-to-date, and compliant with applicable laws. SPARK CPD LTD reserves the right to update this Policy at any time. Employees and third parties will be informed of any changes.