Anti-Bribery Policy

  • Document Reference: ML-ABP
  • Document Version: 2.0
  • Last Updated & Approved: 22/12/2023
  • Review Period: 12 months
  • Next Review Date: 22/12/2024

Table of Content

  • Policy statement
  • Purpose
  • Scope and Applicability
  • What is Bribery?
  • Gifts and Hospitality
  • What is Not Acceptable?
  • Facilitation Payments and Kickbacks
  • Charitable Donations and Sponsorship
  • Record Keeping
  • Responsibilities and Raising Concerns
  • Training and Communication
  • Monitoring and Review

Policy Statement

This is the policy of Main Layer Ltd to conduct business in an honest and ethical manner. As part of that, Main Layer Ltd takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly, and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.


The seller is aware that Main Layer Ltd’s business practices prohibit bribery and corrupt behaviour in any form. The seller agrees that it is an independent contractor, and it is and shall remain in compliance with all applicable laws that relate to commercial or public sector bribes, money laundering, and terrorism (including but not limited to local anti-corruption laws, the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, and the U.K. Bribery Act).

Scope and Applicability

The seller shall not offer or provide anything of value (gifts, loans, travel, entertainment, or any other similar benefit) either directly or indirectly to any government official for the purpose of influencing any act or decision. This means that the supplier cannot pay a gratuity, bribe, or inducement to any government official, even if it appears customary or consistent with prevailing business practices. Prohibited payments include, for example, any payment to a government purchasing agent to influence its decision to purchase products from us; any payment to customs officials to expedite the handling of products being imported or to minimise the amount of duty to be paid; any payment to officials to reduce taxes or expedite the resolution of tax matters; any payment of travel expenses; any contribution to the election campaign of a candidate for government office; or otherwise give a gift (other than one of nominal value) to an official in an agency that may regulate our business or who is a current or potential customer or supplier.

What is Bribery?

A bribe is an inducement or reward offered, promised, or provided in order to improperly gain any commercial, contractual, regulatory, or personal advantage, which may constitute an offence under the act, namely:

  • Giving or offering a bribe;
  • Receiving or requesting a bribe; or
  • Bribing a foreign public official.

What is Not Acceptable?

It is not acceptable for any worker (or someone on their behalf) to:

  • Give, promise to give, or offer, a payment, gift, or hospitality with the expectation or hope that they or Main Layer Ltd will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
  • Give, promise to give, or offer, a payment, gift, or hospitality to a government official, agent, or representative to facilitate or expedite a routine procedure;
  • Accept payment from a third party where it is known or suspected that it is offered or given with the expectation that the third party will improperly obtain a business advantage;
  • Accept a gift or hospitality from a third party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by Main Layer Ltd in return;
  • Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
  • Engage in any activity that might lead to a breach of this policy.

Facilitation Payments and Kickbacks

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.

Charitable Donations and Sponsorship

Main Layer Ltd only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with Main Layer Ltd’s internal policies and procedures.

Record Keeping

We keep appropriate financial records and have appropriate internal controls in place that evidence the business reason for gifts, hospitality, and payments made and received.

Responsibilities and Raising Concerns

The prevention, detection, and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Workers are required to notify us as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve the right to terminate our contractual relationship with non-employee workers if they breach this policy.

Training and Communication

Training on this policy is provided for all workers, and our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors, and business partners.

Monitoring and Review

Main Layer Ltd monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy, and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to provide assurance that they are effective in countering any risks of bribery and corruption.

All workers are aware that they are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing.


Please Note: This document is uncontrolled when printed or copied.

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