Anti-Bribery & Corruption Policy

1. Policy Statement

Xeagle Ltd (trading as X-Eagle) is committed to conducting business ethically, honestly, and in full compliance with the Bribery Act 2010. We have a zero-tolerance approach to bribery and corruption in all our business dealings and relationships.

This policy applies to all employees, directors, drivers (including subcontractors), agents, and anyone acting on behalf of X-Eagle.

2. What is Bribery?

Bribery is offering, promising, giving, accepting, or soliciting an advantage as an inducement for an action which is illegal, unethical, or a breach of trust. Under the Bribery Act 2010, there are four key offences:

• Offering, promising, or giving a bribe
• Requesting, agreeing to receive, or accepting a bribe
• Bribing a foreign public official
• Failure by a commercial organisation to prevent bribery

3. Prohibited Conduct

All personnel are prohibited from:

• Making or accepting any payment, gift, or hospitality intended to influence a business decision
• Making facilitation payments to expedite routine actions
• Offering or accepting gifts or hospitality beyond reasonable business courtesy (maximum value £50)
• Making donations to political parties or causes to gain business advantage
• Using third parties or agents to circumvent this policy

4. Gifts & Hospitality

Modest gifts and hospitality are a normal part of business relationships. However, they must never be used to improperly influence a business decision. All gifts and hospitality over £50 in value must be reported to management and recorded in the gifts register.

5. Due Diligence

X-Eagle conducts appropriate due diligence on all business partners, suppliers, and subcontractors. This includes assessing bribery and corruption risks before entering into business relationships.

6. Record Keeping

We maintain accurate books and records that properly and fairly document all financial transactions. All payments must have a legitimate business purpose and be properly documented and authorised.

7. Reporting Concerns

Anyone who suspects bribery or corruption is encouraged to report it immediately. Reports can be made to:

• Email: ops@xeagle.co.uk
• Phone: +44 7598 247365

All reports will be treated confidentially and investigated promptly. No individual will suffer retaliation for reporting genuine concerns in good faith (whistleblower protection).

8. Consequences

Any breach of this policy will be treated as a serious disciplinary matter and may result in dismissal. Bribery is a criminal offence carrying penalties of up to 10 years imprisonment and unlimited fines.

9. Training & Awareness

All staff receive anti-bribery training as part of their induction. Refresher training is provided annually. This policy is available to all personnel and reviewed annually by management.

10. Review

This policy is reviewed annually by the directors of Xeagle Ltd to ensure it remains current and effective. The next scheduled review is April 2027.

Xeagle Ltd
ops@xeagle.co.uk | +44 7598 247365