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Home Legal Anti-Bribery

Anti Bribery Principles

  • 1. Introduction
    1a. Many of Acuigen’s clients have made public statements on how they are committed to responsible business and good governance, working ethically, lawfully and safely, in a socially responsible way. Acuigen is similarly committed to these principles.
    1b. Acuigen is committed to preventing fraud and ensuring compliance with the UK Economic Crime and Corporate Transparency Act 2023 (ECCTA).
  • 2. Principle 1
    2a. We expect those with whom we do business to abide by these principles of our anti-bribery, anti-fraud and corruption. We insist on honesty, integrity and fairness in all of our business relationships. We will not tolerate any attempt improperly to influence our staff and expect our business partners and suppliers to abide by the principles set out in our anti-bribery and corruption policy.
    2b. We implement our anti-bribery, anti-fraud and corruption programme in all entities over which we have effective control and encourage compliance with the principles of our programme by everyone with whom we have a significant business relationship.
    2c. We encourage contractors, suppliers, business partners, clients and others with whom we engage to speak to Acuigen’s CEO or COO if they become aware of any improper behaviour that could lead to a breach of our anti-bribery or corruption policy.
  • 3. Principle 2
    3a. We do not offer or accept inappropriate gifts or hospitality. We recognise the importance of offering and receiving suitable and proportionate corporate hospitality and gifts. However, we also recognise the potential to use gifts and hospitality as bribes, or for gifts and hospitality to be perceived as bribes.
    3b. We therefore prohibit the offering or receiving gifts or hospitality that could affect, or be reasonably perceived to affect, the outcome of business transactions and are not reasonable or offered or received in good faith.
    3c. We will only approve giving or receiving gifts or hospitality if satisfied the gift or hospitality is not intended to influence the recipient improperly or would be perceived to do so. Receiving or giving gifts without following this procedure could suggest improper behaviour. We will investigate these instances and disciplinary action could follow.
  • 4. Principle 3
    4a. We recognise that facilitation payments are bribes and do not pay them. Facilitation or ‘grease’ payments are small payments made to public officials to secure, or speed-up, routine actions. We prohibit our staff from making facilitation payments as these are bribes that are almost always illegal. We work to ensure that our contractors and suppliers do not make facilitation payments on our behalf.
  • 5. Principle 4
    5a. Our anti-bribery, anti-fraud and corruption policy applies to the contributions we make to our communities. Our employees must ensure that charitable contributions and sponsorship are not used as a subterfuge for bribery or corruption. We will publicly disclose all our charitable contributions and sponsorship.
  • 6. Principle 5
    6a. We maintain effective internal controls to counter bribery, fraud and corruption. We use both organisational and financial checks of our accounting and recordkeeping practices. All transactions are truthfully recorded, reviewed and approved at an appropriate level to ensure payments are not made or received with the intention of influencing the recipient improperly and would not be perceived as doing so.

    • Last updated: 9 December 2025
    Reviewed: 14 April 2026

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