Anti-Bribery and Corruption Policy
Last updated: 30 July 2026 · Document MXR-POL-030 v1.0
1) Purpose
This policy sets out MaxIron Ltd's zero-tolerance position on bribery and corruption. It defines prohibited conduct, the controls that apply to gifts, hospitality, donations and third parties, and the duties of every person who acts for MaxIron Ltd.
It is designed to meet the UK Bribery Act 2010, including the Ministry of Justice guidance on adequate procedures, and to satisfy the anti-bribery expectations of customers, partners and public procurement frameworks under which MaxIron Ltd bids and delivers work.
2) Scope
This policy applies to all directors, officers and employees of MaxIron Ltd; all contractors, consultants, agents, intermediaries and temporary workers engaged by MaxIron Ltd; and any third party authorised to act on MaxIron Ltd's behalf in winning, retaining or performing business.
It applies wherever MaxIron Ltd operates, including the United Kingdom, Ireland, the United States, Europe and any other jurisdiction in which MaxIron Ltd conducts business or engages personnel.
3) Policy statement
MaxIron Ltd does not offer, give, solicit or accept bribes. We will not engage in corruption, kickbacks, facilitation payments or any other improper inducement, whether involving a public official or a private counterparty.
We compete on the quality of our work, the competence of our people and the clarity of our commercial terms. No contract, relationship or personal advantage justifies a breach of this policy.
Breach of this policy is treated as a serious disciplinary matter and may constitute gross misconduct. It may also be a criminal offence for the individual and for MaxIron Ltd.
4) Legal framework
The primary legal framework is the UK Bribery Act 2010, which creates offences of bribing another person, being bribed, bribing a foreign public official, and failure of a commercial organisation to prevent bribery.
MaxIron Ltd also expects compliance with any equivalent anti-bribery and anti-corruption laws that apply in the jurisdictions where we work or where a counterparty is established, including the US Foreign Corrupt Practices Act where relevant to a particular engagement.
5) Prohibited conduct
No person covered by this policy may, directly or indirectly:
- Offer, promise or give a bribe to any person, public or private
- Request, agree to receive or accept a bribe
- Make or authorise a facilitation payment
- Use a third party to do anything this policy prohibits MaxIron Ltd from doing itself
- Offer or accept a gift, hospitality or donation intended to influence, or that could reasonably be perceived as intended to influence, a business or procurement decision
- Keep off-books accounts, false invoices, misleading descriptions or any other record designed to conceal an improper payment
- Retaliate against anyone who refuses to pay or accept a bribe, or who raises a concern in good faith under this policy
There is no materiality threshold that makes a bribe acceptable.
6) Gifts, hospitality and entertainment
Genuine, proportionate gifts and hospitality given or received in the ordinary course of business are permitted within the limits below. They must never be used to influence a decision.
- A clear and legitimate business purpose must exist
- The value and frequency must be reasonable and proportionate
- The gift or hospitality must be open, not secret
- It must not coincide with a tender, contract negotiation, audit, dispute or other sensitive decision in a way that creates an appearance of improper influence
- Cash and cash equivalents are never acceptable
- Gifts or hospitality involving public officials require prior written approval from the Chief Operating Officer, regardless of value
| Activity | Without prior COO approval | Requires prior COO approval |
|---|---|---|
| Gift given or received (per person, per occasion) | Up to £75 | Above £75, or any gift involving a public official |
| Business meal or hospitality (per person, per occasion) | Up to £150 | Above £150, or any hospitality involving a public official |
| Cumulative with the same counterparty in any rolling 12 months | Up to £300 | Above £300 |
All gifts and hospitality at or above £50, and all involving a public official, must be recorded in MaxIron Ltd's Gifts and Hospitality Register within five working days.
7) Facilitation payments
Facilitation payments are prohibited without exception. If a person is placed under immediate threat of violence or unlawful detention unless a payment is made, personal safety comes first. Any such payment must be reported to the Chief Operating Officer as soon as it is safe to do so, recorded accurately, and escalated for legal review.
8) Political and charitable donations
MaxIron Ltd does not make political donations, and no person may make a political donation on MaxIron Ltd's behalf or in MaxIron Ltd's name.
Charitable donations by MaxIron Ltd require prior written approval from the Chief Operating Officer, must be made to a registered charity or equivalent regulated body, must have a legitimate philanthropic purpose, must not be linked to winning or retaining business, and must be recorded accurately in the company's books.
9) Third parties, agents and intermediaries
MaxIron Ltd can be liable for bribery committed by associated persons acting on its behalf. Before engaging an agent, introducer, reseller, joint-venture partner or other intermediary who will interact with customers or public bodies on MaxIron Ltd's behalf, proportionate due diligence is completed, a written agreement includes anti-bribery obligations, compensation is commercially reasonable and linked to legitimate services, and unusual payment requests are escalated and not processed until cleared.
10) Books and records
All transactions must be recorded accurately, completely and promptly. No person may create or use false, incomplete or misleading records, establish undisclosed funds or assets, or mischaracterise the nature, purpose or recipient of a payment.
11) Reporting concerns
Anyone covered by this policy who becomes aware of actual or suspected bribery, corruption or a breach of this policy must report it promptly to the Chief Operating Officer at ivan.milic@maxiron.co.uk, or to the CEO where the concern involves the Chief Operating Officer.
Good-faith reports are protected. MaxIron Ltd will not tolerate retaliation against anyone who raises a genuine concern or who refuses to engage in conduct prohibited by this policy. Nothing in this policy prevents a person from reporting a suspected criminal offence to the police or other competent authority.
12) Investigation and consequences
Reports are assessed promptly. Where investigation is warranted, it is conducted fairly and, so far as practicable, confidentially. Confirmed breaches may result in disciplinary action up to and including dismissal for gross misconduct, termination of contractor or supplier agreements, recovery of improperly conferred advantages where lawful, and referral to law enforcement or regulators.
13) Responsibilities
- Board / CEO: set the tone of zero tolerance, approve this policy, and ensure adequate resources for implementation.
- Chief Operating Officer: own the policy, maintain the Gifts and Hospitality Register, approve exceptions, oversee higher-risk intermediary diligence, receive and investigate reports, and escalate material matters to the CEO.
- Managers: ensure their teams understand and apply this policy, lead by example, and escalate concerns without delay.
- All personnel and associated persons: comply, seek advice where uncertain, record gifts and hospitality as required, and report actual or suspected breaches.
14) Related policies
This policy is read with MaxIron Ltd's internal Expenses Policy, Disciplinary and Grievance Policy, supplier due-diligence procedures, and awareness and training programme. See also our Terms of Use and Trust Centre.
15) Contact
Questions about this policy: office@maxiron.com
MaxIron Ltd, 3rd Floor, 86–90 Paul Street, London, England, EC2A 4NE.