Anti-Corruption and Bribery Policy
1. Purpose
1.1 nowhere group ltd ("nowhere" / "the Company" / "we") is committed to conducting all of its business activities with integrity, transparency, and fairness. We have zero tolerance for bribery, corruption, or any form of improper influence.
1.2 This policy exists to protect our people, our clients, and our reputation by setting out clear expectations for ethical behaviour. It reflects our wider commitment to responsible business practices, trust-based relationships, and acting in ways that positively contribute to the systems and organisations we work with.
2. Scope
2.1 This policy applies to all employees of nowhere ("Staff").
2.2 Where relevant, it also applies to contractors, associates, and any third parties acting on behalf of the Company.
3. Objectives
3.1 To prevent bribery and corruption in all forms.
3.2 To ensure compliance with applicable anti-corruption and bribery legislation, including the UK Bribery Act 2010.
3.3 To provide clear guidance on acceptable and unacceptable conduct.
3.4 To protect Staff from situations that could place them at personal or professional risk.
3.5 To uphold trust and integrity in all relationships with clients, partners, and suppliers.
4. Responsibilities of nowhere
The company will:
4.1 Communicate this policy clearly and make it accessible to all Staff.
4.2 Take reasonable steps to prevent bribery and corruption in our operations and business relationships.
4.3 Provide guidance and support to Staff who are unsure how to apply this policy in practice.
4.4 Investigate any suspected breaches promptly, fairly, and confidentially.
4.5 Take appropriate disciplinary action where breaches are identified.
4.6 Review this policy regularly to ensure it remains effective and aligned with best practice.
5. Responsibilities of Staff
All Staff are expected to:
5.1 Act honestly, ethically, and in good faith in all business dealings.
5.2 Not offer, promise, give, request, or accept bribes or improper advantages of any kind.
5.3 Avoid situations where personal interests could conflict with the interests of the Company.
5.4 Declare and seek guidance on any gifts, hospitality, or benefits that could be perceived as influencing decisions.
5.5 Raise concerns promptly if they suspect bribery, corruption, or unethical conduct.
5.6 Cooperate fully with any investigation relating to this policy.
6. Gifts, Hospitality and Expenses
Reasonable, proportionate, and transparent gifts or hospitality may be acceptable where they:
6.1 Are infrequent and modest in value.
6.2 Are given for legitimate business purposes.
6.3 Do not create an obligation or expectation of preferential treatment.
6.4 Would not cause reputational damage if disclosed publicly.
6.5 Cash payments, facilitation payments, or personal benefits are strictly prohibited.
6.6 When in doubt, Staff must seek guidance from the HR Management Team before offering or accepting any gift or hospitality.
7. Support Measures
To support ethical and compliant behaviour, nowhere will:
7.1 Provide clear guidance on handling gifts, hospitality, and conflicts of interest.
7.2 Encourage a culture where concerns can be raised without fear of retaliation.
7.3 Ensure confidentiality and fairness for anyone raising a concern in good faith.
7.4 Signpost Staff to further advice or escalation routes where needed.
8. Personnel Responsible for this Policy
8.1 The HR Management Team has overall responsibility for the effective operation of this policy and shall be responsible for reviewing this policy to ensure that it meets legal requirements and reflects best practice.
9. Contact Information
9.1 For any questions or concerns relating to this policy, please contact the HR Management Team at hr@now-here.com. Alternatively, members of the HR Management Team may be contacted individually using their company email addresses.
10. Breaches of Policy
10.1 nowhere will take appropriate measures to remedy any breach of the policy and its associated procedures and guidelines. In the case of Staff then the matter may be dealt with under the disciplinary procedures.