Anti-Bribery & Corruption Policy

ANTI-BRIBERY & CORRUPTION POLICY

Fixiz Ltd — Company No: 14561967

Policy Start Date: 28 March 2026  |  Review Date: 28 March 2027

1. Statement of Commitment

Fixiz Ltd is committed to conducting all business activities with honesty, integrity, and full compliance with the Bribery Act 2010. We operate a zero-tolerance approach to bribery and corruption in all its forms, whether direct or indirect, and in all countries where we operate.

This policy applies to all directors, employees, contractors, subcontractors, agents, and any third parties acting on behalf of Fixiz Ltd.

2. What is Bribery?

Bribery is the offering, giving, receiving, or soliciting of any financial or other advantage in order to improperly influence an action or decision. This includes:

• Offering or giving bribes to public officials or private individuals
• Receiving or requesting bribes
• Bribing a foreign public official
• Failing to prevent bribery by an associated person acting on behalf of Fixiz Ltd

3. Scope and Application

This policy applies to:

• All employees (full-time, part-time, temporary)
• Directors and senior management
• Contractors and subcontractors working on Fixiz projects
• Agents, consultants, and third-party representatives
• Any person or organisation associated with Fixiz Ltd

4. Gifts and Hospitality

Fixiz Ltd recognises that gifts and hospitality can form part of normal business practice. However, we will never offer or accept gifts or hospitality that could be perceived as an attempt to gain a business advantage. Specifically:

• No gifts of significant monetary value shall be offered or accepted
• Reasonable and proportionate hospitality (e.g., a working lunch) is permissible if transparent and properly recorded
• Gifts of cash or cash equivalents are strictly prohibited
• All gifts and hospitality received or offered above £25 in value must be declared to management

5. Political and Charitable Contributions

Fixiz Ltd does not make contributions to political parties. Any charitable donations made by the company will be lawful, transparent, and must not be made with the intention of gaining a business advantage.

6. Due Diligence

Fixiz Ltd will apply due diligence procedures in respect of third parties who perform services or undertake transactions on the company's behalf. This includes:

• Assessing the bribery and corruption risk of all third-party relationships
• Conducting appropriate background checks on agents and intermediaries
• Including anti-bribery compliance clauses in contracts with third parties
• Monitoring ongoing relationships to identify any suspicious conduct

7. Responsibilities

7.1 Director / Senior Management

• Ensure this policy is implemented and communicated across the business
• Set the ethical tone for the organisation
• Allocate appropriate resources to anti-bribery compliance
• Review this policy annually

7.2 All Staff, Contractors and Associates

• Read, understand and comply with this policy
• Refuse any offer of a bribe or inappropriate advantage
• Report any suspicion of bribery immediately
• Never threaten or penalise anyone who raises concerns in good faith

8. Reporting and Whistleblowing

Any individual who suspects bribery or corruption has occurred or is about to occur must report it immediately. Reports can be made to:

• Director: Javier Vazquez
• Email: info@fixiz.co.uk

All reports will be treated in strict confidence. Fixiz Ltd will not tolerate any retaliation against any person who raises a genuine concern in good faith, even if the concern turns out to be unfounded.

9. Consequences of Breach

Any breach of this policy by an employee will be treated as a serious disciplinary matter and may result in:

• Immediate suspension pending investigation
• Summary dismissal
• Referral to the relevant law enforcement authorities

Third parties found to be in breach of this policy may have their contracts terminated immediately.

Under the Bribery Act 2010, individuals found guilty of bribery can face up to 10 years imprisonment and/or an unlimited fine. Companies can face an unlimited fine.

10. Training and Awareness

Fixiz Ltd will ensure that:

• All relevant staff receive training on the requirements of the Bribery Act 2010 and this policy
• Training records are maintained
• New employees and contractors are made aware of this policy during induction

11. Monitoring and Review

This policy will be reviewed annually by the Director of Fixiz Ltd, or sooner if:

• There are changes in relevant legislation or guidance
• A breach of the policy has occurred
• There are significant changes to our business operations or associated third parties

12. Signature and Approval

This Anti-Bribery & Corruption Policy is approved and endorsed by senior management of Fixiz Ltd.

NOTE: This policy is to be read in conjunction with our Terms & Conditions, Privacy Policy, and all applicable UK legislation including the Bribery Act 2010.