Our anti-bribery and corruption policy.

Purpose and statement

Pametan Ltd (“Pametan”, “we”) is committed to the highest standards of ethical conduct and integrity. We have a zero-tolerance approach to bribery and corruption in every part of our business — including everything we do for, and on behalf of, our clients.

The UK Bribery Act 2010 creates four offences: bribing another person, being bribed, bribing a foreign public official, and (under section 7) a commercial organisation failing to prevent bribery by people associated with it. The first three offences carry up to 10 years’ imprisonment for individuals and unlimited fines for organisations. This policy is one of the things we have in place to discharge the section 7 obligation; it is not the only thing.

We expect everyone covered by this policy to read it, understand it and apply it. If you’re not sure how it applies to a particular situation, ask the Founder before you act — not after.

Who this applies to

This policy applies to anyone working for or on behalf of Pametan, in any capacity, anywhere in the world. That includes:

• Permanent and fixed-term employees.
• Directors of the Board.
• Contractors, sub-contractors and freelancers engaged by Pametan.
• Agency workers and interns.
• Anyone acting on Pametan’s behalf in any other capacity — including, where relevant, our suppliers (see our Supplier Code of Conduct).

For the rest of this document, where we refer to “you” we mean any of the above. Where we refer to “we” we mean Pametan as the organisation.

What we mean by bribery and corruption

We use these terms in line with the UK Bribery Act 2010 and the Ministry of Justice’s published guidance.

Briberyis offering, promising, giving, requesting, agreeing to receive or accepting anything of value — money, gifts, hospitality, services, employment, contracts, anything — with the intention of influencing a person’s behaviour in a way that’s improper. “Improper” includes a breach of trust, a breach of duty, or an action that a reasonable person in the UK would regard as improper.

Corruption is the abuse of an entrusted position for private gain. It overlaps with bribery but is broader — it also covers things like kickbacks, embezzlement, fraud and certain conflicts of interest.

A facilitation payment is a small payment made to a public official to speed up or secure a routine action that the official is already obliged to perform. They are illegal under the Bribery Act, with very limited exceptions (genuine duress where life or safety is threatened).

A kickback is a payment made as a thank-you for awarding work or a contract. Kickbacks are bribes. We treat them identically.

Our position

We will not:

• Offer, give, promise, request or accept a bribe in any form, anywhere, ever.
• Make or facilitate a payment that has the purpose of influencing a public official’s decisions improperly.
• Use third parties — agents, intermediaries, sub-contractors — to do anything we would not do ourselves under this policy.
• Retaliate against anyone who refuses to engage in bribery or who reports a concern in good faith (see our Whistleblowing procedure).

This applies whether the counterparty is private-sector or public-sector, in the UK or abroad, large or small. The Bribery Act has extra-territorial reach — a UK company can be liable for bribery committed by an associated person anywhere in the world.

Gifts, hospitality and entertainment

Modest gifts and hospitality are a normal part of business relationships. The Bribery Act doesn’t prohibit them. It does require us to apply judgement — and to record what we do.

Our approach is proportionate to the size of our business. The thresholds and rules below apply per person, per twelve-month period, across all interactions with the same counterparty.

What you can do without seeking approval

• Give or accept a gift of nominal value — up to £75 per recipient. Branded merchandise (a notebook, a mug) is almost always fine.
• Provide or accept hospitality of nominal value — up to £150 per person per event (lunch, dinner, an industry talk).
• Reasonable promotional expenditure — for example, a conference booth or a sponsored speaker slot — that’s openly advertised and applies to all attendees equally.

What needs the Founder’s prior written approval

• Any gift or hospitality over the thresholds above.
• Any gift or hospitality of any value to a public official — including any person performing a public function on behalf of a regulator, central bank, government department, court or local authority.
• Cash or cash equivalents of any value (these are never appropriate as a business gift, regardless of amount).
• Anything where there is any contract negotiation, tender, regulatory decision or commercial decision pending with the same counterparty.

What is always prohibited

• Gifts of cash or cash equivalents (gift cards, cryptocurrency, vouchers redeemable for cash).
• Gifts or hospitality given with the intent — or appearance — of influencing a specific decision.
• Gifts to or hospitality with a person’s family members where the underlying business relationship is with that person.
• Anything that, if reported in tomorrow’s Financial Times, would be reported as inappropriate.

Every gift or hospitality you give or receive — whether or not it requires prior approval — must be recorded in the Pametan gifts & hospitality register within five working days. The Founder reviews the register quarterly.

Facilitation payments

Facilitation payments are bribes. We do not make them.

The only narrow exception is where there is a genuine and immediate threat to life or personal safety — for example, a demand made under coercion at a border crossing in a high-risk jurisdiction. In that situation, your safety takes priority over this policy. Make the payment, leave the situation, and report it to the Founder as soon as you are safe so that we can document it and review our procedures.

Political and charitable contributions

Pametan does not make political donations of any kind in any jurisdiction. This is unconditional.

Charitable contributions are permitted but must be approved in writing by the Founder. We don’t make charitable contributions where the recipient charity, or any person associated with it, is in a position to influence a Pametan business decision — for example, a charity closely connected to a current or prospective client.

Personal political and charitable activity by people working for Pametan is your own business, provided it is not conducted using Pametan resources, name or time, and does not give the appearance of being Pametan’s position.

Third-party risk and due diligence

The Bribery Act makes us responsible for bribery committed by “associated persons” — people performing services for us or on our behalf. Before engaging a new third party in a category that carries bribery risk (for example: lobbyists, agents acting on our behalf with public-sector buyers, introducers, intermediaries), the Founder will conduct proportionate due diligence. Proportionate means looking — at minimum — at:

• The third party’s reputation and any public sanctions, debarment or adverse media.
• Their published anti-bribery policy, where they have one, and ours, where they don’t.
• The country or sector they operate in (Transparency International’s Corruption Perceptions Index is a starting point).
• Whether the engagement and its fee structure are commercially explicable.

Higher-risk engagements are approved in writing and contractually require the third party to comply with this policy.

Record keeping

We keep clear, accurate records of all business transactions, including a gifts & hospitality register, a third-party due-diligence file, and records of any concerns raised under this policy (or the Whistleblowing procedure). Records are retained for seven years after the end of the relevant relationship or transaction.

Training

Everyone covered by this policy receives bribery and corruption training within their first month of joining or engaging with Pametan, and refresher training every two years. Higher-risk roles — finance, sales, anyone interacting with public officials — receive additional role-specific training. Training is documented; the Founder reviews completion annually.

Reporting concerns

If you suspect bribery, corruption or any breach of this policy — by anyone at Pametan, by a client, by a supplier, or by anyone acting on our behalf — you must raise it.

Use the Whistleblowing procedure. It includes the right to report directly to a prescribed external regulator under PIDA 1998 without raising the matter internally, so it is safe to use even if your concern is about the Founder.

You will not suffer retaliation, detriment or victimisation for raising a concern in good faith. This is a contractual commitment and, under the Public Interest Disclosure Act 1998, a legal one.

Consequences of breach

Breach of this policy is a serious matter. Depending on the circumstances, it may result in:

• Disciplinary action up to and including immediate dismissal for employees, or termination of contract for contractors and suppliers.
• Civil and criminal liability — both for the individual and, where applicable, for Pametan.
• Reporting to the relevant regulator and to the police.
• Recovery of any loss or unjust enrichment.

Our adequate procedures

The Ministry of Justice’s guidance on the Bribery Act sets out six principles for adequate procedures. Here is how each maps to what Pametan does. As we grow, each will become more formal.

• Proportionate procedures. This policy, the gifts register, the due-diligence file and the related procedures we hold internally — sized to a small consultancy operating in the UK, US and Canada with a small supplier base and no current public-sector engagements.
• Top-level commitment. The Founder owns this policy. The Founder reads every quarterly gifts-register review personally. This commitment is in writing in this published document.
• Risk assessment. We conduct an annual bribery and corruption risk assessment covering jurisdictions, sectors, third parties, public-official exposure and business activities. Results inform this policy at each annual review.
• Due diligence. Proportionate due diligence on third parties, as described in §Third-party risk.
• Communication and training. This policy is published. New joiners are trained within their first month. Refresher training is two-yearly. The Whistleblowing procedure is published and accessible.
• Monitoring and review. Annual policy review, quarterly gifts-register review, any concerns raised investigated promptly. Changes to the policy are recorded in the document control section below.

Related policies

• Whistleblowing procedure
• Supplier Code of Conduct
• Sustainability policy
• Modern Slavery statement
• Privacy Policy

Contact

Questions about this policy go to the Founder at hello@pametan.co. Concerns or suspected breaches go through the Whistleblowing procedure— including, if you’d prefer not to raise the matter internally, directly to a prescribed external regulator under PIDA 1998.

Pametan Ltd · Companies House No. 16023621 · Registered office: 20 Wenlock Road, London N1 7GU. This policy is published in plain English; if you need it in an alternative format, write to hello@pametan.co. Useful external resources: the UK Ministry of Justice’s Bribery Act guidance, Transparency International UK, and the Serious Fraud Office.