Anti-Bribery and Corruption

What This Policy Covers

This policy applies to all individuals working at any level — including employees, contractors, directors, interns, consultants, volunteers, and agents — representing Wise Galleria Limited, wherever they are located.

Wise Galleria is committed to conducting business ethically and transparently. We do not tolerate bribery or corruption in any form and enforce a zero-tolerance approach in every business interaction.

Definition of Bribery

A bribe is any gift, payment, or favour intended to influence a business or official decision. Under the Bribery Act 2010, both giving and receiving bribes are criminal offences. Offenders may face up to 10 years imprisonment and unlimited fines.

Wise Galleria and its representatives must not give or accept bribes under any circumstance, and must report any suspected activity immediately.

Your Responsibilities

• Read and understand this policy.
• Refuse any offer or request that could constitute bribery.
• Report any suspicion of bribery immediately.

All staff must comply and cooperate with our procedures for preventing bribery.

Gifts & Hospitality

Reasonable hospitality or gifts are permitted, if:

• They’re not meant to influence decision-making
• They comply with UK law
• No cash or vouchers are included
• They’re appropriate and given openly

Approval must be obtained from the Managing Director prior to offering or accepting gifts.

Unacceptable Practices

Do NOT:

• Offer or receive anything in exchange for business advantage
• Give gifts to government officials without approval
• Threaten or retaliate against anyone who reports bribery

Facilitation Payments

We prohibit "kickbacks" or unofficial facilitation payments. If asked to make such a payment:

• Question the request
• Ask for a receipt and explanation
• Report to the Managing Director immediately

Record-Keeping

All gifts, expenses, and hospitality must be declared and recorded. Records must be accurate and reflect the true nature of each transaction.

Receipts and justifications should be submitted per our expenses policy.

Reporting Concerns

Report any suspicious behaviour to the Managing Director. Use our internal Whistleblowing Policy where appropriate.

We encourage openness and offer full protection for genuine reports made in good faith.

Training & Communication

Anti-bribery training is part of every team member’s onboarding process. Refresher training may be required for certain roles.

Suppliers and partners will be made aware of this policy during the onboarding phase.

Management Responsibility

The Managing Director is responsible for policy enforcement and compliance. Managers are accountable for ensuring their teams understand and follow this policy.