Anti-Bribery & Corruption Policy

1. Policy Statement

Delta Force Group Ltd conducts business honestly, transparently and with integrity. We operate a zero-tolerance approach to bribery and corruption in all forms, in every market and jurisdiction in which we work.

We are committed to acting professionally, fairly and in accordance with the Bribery Act 2010 and all other applicable anti-bribery and anti-corruption legislation, and to implementing and enforcing effective systems to counter bribery.

2. Scope

This policy applies to all employees, directors, officers, agency workers, contractors, sub-contractors, consultants, agents, intermediaries and suppliers acting for or on behalf of Delta Force Group Ltd.

3. Definitions

• Bribe: a financial or other advantage offered, promised, given, requested or accepted to induce or reward improper performance of a function or activity.
• Corruption: the abuse of a position of trust for personal or commercial gain.
• Facilitation payment: a small unofficial payment made to secure or speed up a routine action.
• Kickback: a payment or benefit made in return for a business favour or advantage.

4. What Is Prohibited

Personnel and third parties acting for us must never, directly or through another person:

• Offer, promise, give, request, agree to receive or accept a bribe
• Make or accept a facilitation payment or kickback of any kind
• Offer or accept a benefit intended to influence the award of a contract, tender, licence or approval
• Offer or accept a benefit to influence a public official or regulator
• Make political donations on behalf of the company
• Make a charitable donation intended to obtain a business advantage
• Engage in cartel behaviour, bid-rigging, price fixing or collusive tendering
• Falsify records, invoices, timesheets or expenses to conceal any of the above
• Threaten or retaliate against anyone who refuses to pay a bribe or who reports a concern

5. Gifts and Hospitality

This policy does not prohibit reasonable and proportionate hospitality given or received in the normal course of business. Gifts and hospitality are only acceptable where they:

• Are not intended to influence a decision or obtain an improper advantage
• Are of modest value, reasonable and proportionate
• Are given openly and not in secret, and never in cash or cash equivalent
• Are given in the company's name rather than an individual's
• Comply with the recipient organisation's own rules, including public sector procurement rules
• Are not offered or accepted during a live tender, bid or contract award process

Any gift or hospitality that could create a perception of improper influence must be declined and reported to a director. Offers and acceptances above a nominal value must be declared for recording in the company's gifts and hospitality register.

6. Conflicts of Interest

Personnel must declare any personal, financial or family interest that could conflict, or appear to conflict, with the interests of the company or a client — including relationships with suppliers, sub-contractors, competitors or client decision-makers. Declared conflicts will be recorded and managed, and the individual concerned will be removed from the relevant decision where appropriate.

7. Supply Chain and Third Parties

• Proportionate due diligence is carried out on suppliers, sub-contractors and agents
• Anti-bribery expectations are communicated as part of our procurement and onboarding process
• Payments must be properly authorised, supported by an accurate invoice and made to the contracted entity
• Concerns about a third party are escalated and may result in suspension or termination of the relationship

These arrangements operate alongside our Modern Slavery Statement and wider supplier due diligence.

8. Record Keeping

We maintain accurate and complete books, records, accounts and expense claims. All expenses relating to hospitality, gifts or payments to third parties must be recorded truthfully, with the reason clearly stated. No off-book account or undisclosed arrangement may be used for any purpose.

9. Responsibilities

• All personnel must comply with this policy, avoid any activity that could breach it and report concerns promptly.
• Managers must ensure their teams understand the policy, escalate concerns and prevent retaliation.
• Directors are responsible for the adequacy of procedures to prevent bribery, for reviewing risk and for enforcing this policy.

10. Raising a Concern

Anyone who is offered a bribe, is asked to make one, or suspects that bribery or corruption has occurred must report it as soon as possible under our Whistleblowing Policy. Concerns raised honestly and in good faith will be treated confidentially and without retaliation.

11. Consequences of Breach

Breach of this policy is a serious matter. It may result in disciplinary action up to and including dismissal for gross misconduct, termination of a contract or supplier relationship, and referral to the police or other authorities. Individuals and the company may also face criminal prosecution, unlimited fines and, for individuals, imprisonment under the Bribery Act 2010.

12. Related Policies

• Whistleblowing Policy
• Modern Slavery Statement
• Quality Policy
• Data Protection Policy
• Complaints Policy
• Human Rights & Stakeholder Governance

13. Monitoring and Review

Bribery and corruption risk, declared gifts and hospitality, conflicts of interest and reported concerns are monitored as part of our governance and compliance activity. This policy is reviewed annually, or sooner where legislation, client requirements or business risk change, or following an incident or audit recommendation.