Anti-Bribery & Corruption



MLM Limited’s policy is to conduct our business according to ethical, professional and legal standards in a fair, honest and open manner. This policy is implemented with a zero-tolerance approach with effective systems to counter bribery as its effect on MLM and our business partners may harm our reputation and run the risk of criminal prosecution.  We uphold all laws relevant to counter bribery and corruption and are bound by the Bribery Act 2010.


The purpose of this policy is to set out our responsibilities and of those working for us in observing and upholding our position on bribery and corruption which is a Criminal Offence.



Who is covered by this policy?


This policy applies to all individuals working at all levels, including Directors, consultants and employees, contractors, and any other person associated with MLM.



What is Bribery?


A bribe is an inducement or reward which is offered, promised or provided in order to gain improperly any commercial, contractual, regulatory or personal advantage.


Bribery and corruption can take many forms. It is not possible to provide an exhaustive list of examples which may be made directly or indirectly through a third party. However some examples may include:

  • The direct or indirect promise, offering or authorisation of anything of value.
  • The offer or receipt of any kickback, loan, fee, reward or other advantage.
  • The giving of aid, donations or voting designed to exert improper influence.  Payments for lavish or inappropriate entertainment or travel.
  • Favours including offers of employment.
  • Facilitation payments.
  • Inflated commissions.
  • Fake consultancy agreements.

“Anything of value” includes cash, gifts, travel expenses, entertainment, offers of employment, provision of free services, and business meals. It may also include event sponsorships, consultant contracts, fellowship support and charitable contributions made at the request of, or for the benefit of, an individual, his or her family, or other relations, even if made to a legitimate charity.



Gifts and Hospitality


The giving or receiving of gifts in the normal course of business is not prohibited where such seeks to improve the image of the company and its services or to establish or cement relations which will be considered an acceptable part of doing business.

The gift or hospitality must be reasonable and proportionate and must conform to the following requirements:

  • It is not made with the intention of influencing a third party to obtain or retain business or a business advantage or to reward the provision of retention of business or the in explicit or implicit exchange of favours or benefits.
  • It does not include cash or cash equivalents such as vouchers.
  • It is appropriate for the circumstances in terms of type, value, and given at an appropriate time.
  • It is given openly and not secretly.

The test to be adopted will be whether the gift or hospitality in all the circumstances is reasonable and justifiable.  The intention behind the gift or hospitality should always be considered.



Kickbacks and Facilitation Payments


Kickbacks are typically payments made in return for a business favour or advantage. Kickbacks usually involve the return of a percentage of a sum of money already requested or received, typically as a result of pressure, coercion or a secret agreement. A kickback can be initiated and received by a corrupt individual, usually simultaneously with or after the completion of a business transaction.


Facilitation payments are typically small, unofficial payments made to secure or expedite or facilitate a routine government or administrative action by a government official. They are not commonly paid in the UK but are common in some other jurisdictions.


Kickbacks and facilitation payments are prohibited in all forms.



Employees’ responsibility


All employees’ must read and understand and comply with this policy.


The prevention, detection and reporting of bribery is the responsibility of all employees.


You must report to a director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.


MLM is committed to encouraging employees to be vigilant and to report any suspicion of bribery.


MLM will investigate with appropriate sensitivity all instances of alleged bribery and assist the police and other authorities in any resultant prosecution.


MLM will take appropriate disciplinary action against any individual(s) involved in bribery.


Failure to comply with this policy may result in disciplinary action, including dismissal (employees), or appropriate sanctions (business directors) in addition to civil or criminal charges.



MLM Policy


MLM opposes all forms of bribery and corruption at any time whether large or small from any person, company or organisation or charity.


MLM prohibits the offer, gift or acceptance of a bribe in any form, including kickbacks on any portion of a contract payment, facilitation payments or the use of other routes or channels to provide improper benefits to customers, agents, contractors, suppliers or employees of any such party.


MLM prohibits any company personnel or business partner from arranging or accepting a bribe, facilitation payment or kickback from customers, agents, contractors, suppliers, or employees of any such party, for their own benefit or that of their family, friends, associates or acquaintances.


MLM employees and consultants must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by MLM.


If any employee of consultant of MLM is confronted with a request or demand for an improper payment or other violation of company policy, the request or demand must be immediately rejected and reported to the directors.



Monitoring and Review


The directors will monitor and review the implementation of this standard operating procedure regularly and access its effectiveness.  Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.


Ref:  1546  Version:  2  Created by:  SJ  Review Date:  27/06/2025