Our commitment

We prohibit bribery and corruption in every form, in every market, without exception. We do not pay or accept bribes, and we do not make facilitation payments, even where they are locally common.

Scope

This policy applies to everyone who works for or with Equity House Group Limited, including employees, directors, contractors, freelancers, interns, volunteers, advisors and, where stated, our suppliers and partners.

What is prohibited

• Offering, giving, requesting or accepting anything of value to improperly influence a decision
• Facilitation or grease payments to speed up routine processes
• Political donations made on behalf of Equity House
• Charitable donations or sponsorships used to obtain a business advantage
• Using a third party, agent or intermediary to do any of the above

Gifts and hospitality

Modest, proportionate and openly given hospitality is acceptable. Anything that could reasonably influence a decision, or be seen to, must be declined and recorded. See our gifts and hospitality policy for thresholds.

Records

All payments must be accurately recorded. No off-book accounts, false invoices or misleading descriptions are permitted under any circumstances.

Raising a concern

If you have a concern about a payment or offer that may amount to bribery, raise it with your manager or email contact@equityhouse.io. Concerns can be raised confidentially and you will never be penalised for speaking up in good faith. See our whistleblowing policy for the full route.

Governance and review

This policy is owned by the Chief Operating Officer and approved by the board. It is reviewed at least annually, and sooner if the law, our operations or our risk profile changes.