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Anti-Bribery and Corruption Policy


Bribery is, in the conduct of Ultimate Battery Company(UBC) business, the offering, giving, promising, agreeing, receiving, accepting or soliciting something of value or of an advantage in order to induce or influence an action or decision.

Bribery is a criminal offence under the Bribery Act 2010.

Bribery is a form of corruption. Corruption is the misuse of office or power for private gain.


The purpose of this policy is to convey to all employees and interested parties the rules of UBC in relation to our unequivocal stance towards the eradication of corrupt behaviours and our commitment to ensuring that UBC conducts its business in a fair, professional and legal manner.

We require compliance from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero- tolerance attitude towards corrupt activities of any kind, whether committed by UBC employees or by third parties acting for or on behalf of UBC.


Under the Bribery Act 2010, it is a criminal offence to:

  • offer a bribe;
  • accept a bribe;
  • bribe a foreign official;
  • as a commercial organisation, to fail to prevent a bribe.

Anyone found guilty by a court of the above offences could be imprisoned and/or receive an unlimited fine. UBC could also face prosecution and be liable to pay a fine.


This policy applies to all employees of UBC, regardless of seniority or where they are located. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement. We will encourage the application of this policy where our business involves the use of third parties e.g. suppliers, contractors.


It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company, anywhere in the world, in order to gain commercial, contractual or regulatory advantage for UBC, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical. This includes any payments to a third party on behalf of an individual or company.

If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact the Chief Executive so that action can be taken if considered necessary. You may be asked to give a written account of events.

If you, as an employee or person working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this to the Chief Executive. You may be asked to give a written account of events. Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.

UBC will ensure that all its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.

UBC takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.

We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, an agency worker, contractor etc as well as potential legal action.

Staff are reminded of UBC’s Whistleblowing Policy which is available from HR.

Gift and hospitality

We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.

You should not accept or provide any gift or hospitality if acceptance will give the impression that you have been influenced in an “official capacity”.

All gifts/hospitality, whether accepted or declined, must be declared to the Chief Operating Officer who will maintain a Gifts and Hospitality Register. If you have any questions in relation to this policy, you should raise these with the Chief Operating Officer.

Small gifts up to a value of £25, such as pens, calendars, or flowers, received as a mark of friendship or appreciation, may be accepted by the individual.

Hospitality should only be accepted where there is a direct link to working arrangements and a genuine business reason can be demonstrated, for example:

  • attendance or speaking at a conference, which provides complimentary subsistence, travel and accommodation (this does not need to be declared on the register except where a gift was received, see paragraph 6.3);
  • attending a free training course; or
  • attending a drinks reception to network.

Hospitality invitations to events which are purely social events should not be accepted. You may not accept free holidays from a current or potential contractor. These invitations should be recorded in the register, even though they have been declined.

No gift should be given, nor hospitality offered by an employee or anyone working on UBC’s behalf to any party in connection with our business without receiving prior written approval from the Chief Executive. In exceptional circumstances, and subject to the approval of the Chief Executive, it may be appropriate for UBC to provide a gift with a value of up to £25, for example:

  • providing a bouquet of flowers to a seriously ill employee, or to a longstanding employee
  • who is retiring; or
  • giving book tokens to someone who spoke at an UBC conference free of charge.


The Gifts and Hospitality Register will be reviewed quarterly by the Audit and Risk Group to ensure compliance with this policy.

Policy breach

Employees who fail to follow this policy may be subject to disciplinary action under UBC’s Disciplinary Procedure. For other workers, a review of the contract of engagement will be undertaken.