Anti-Bribery Policy

1. Purpose

This policy sets out the standards we expect of everyone at EBA Group Limited in relation to bribery and corruption. It applies to all partners, employees, contractors and anyone acting on our behalf.

Bribery is a criminal offence. Under the Bribery Act 2010, individuals convicted of bribery face up to 10 years' imprisonment and unlimited fines. The firm itself can face unlimited fines and reputational damage. This policy exists to prevent that from happening — not as a threat, but because doing the right thing is central to who we are.

2. What Is Bribery?

Bribery means offering, promising, giving, requesting or accepting a financial or other advantage to influence a person's actions or decisions improperly. It does not matter whether the bribe is direct or through a third party, or whether it involves cash, gifts, favours or any other benefit.

The Bribery Act 2010 creates four offences:

• Bribing another person (offering or giving an advantage to induce improper conduct)
• Being bribed (requesting or accepting an advantage in return for improper conduct)
• Bribing a foreign public official
• Failure by a commercial organisation to prevent bribery (the "corporate offence")

The corporate offence is the one that applies most directly to eba. The only defence is to prove we had "adequate procedures" in place to prevent bribery. This policy is part of those procedures.

3. What This Means in Practice

In a professional services firm, bribery risk does not typically look like suitcases of cash. It looks like:

• A client offering to pay for an expensive dinner in exchange for a favourable audit opinion or tax position
• A supplier offering tickets to an event in return for being recommended to clients
• Paying a referral fee to someone for introducing clients without disclosing it
• Making a charitable donation at a client's request to a charity where the client sits on the board, in exchange for continued business
• Offering to expedite work or provide preferential treatment in return for personal favours

If you are unsure whether something crosses the line, apply this test: would you be comfortable if the arrangement were reported in the local press? If not, do not proceed without seeking guidance.

4. Gifts and Hospitality

4.1 General Rule

Modest, proportionate gifts and hospitality are a normal part of business relationships. They become a problem when they create an obligation, influence a decision, or could reasonably be seen to do so.

4.2 Thresholds

The following thresholds apply:

• Gifts under £50 in value: May be given or accepted without prior approval, provided they are not frequent and do not create a pattern. Record them in the gifts register.
• Gifts between £50 and £150: Must be approved in advance by David Elliott (or Mike Scott if the gift involves David). Record in the register.
• Gifts over £150: Not permitted without exceptional justification and approval from both partners.
• Cash or cash equivalents (vouchers, gift cards): Never acceptable, regardless of value.

4.3 Business Entertainment

Working lunches, client dinners and networking events are part of professional life. Apply common sense:

• A sandwich lunch during a meeting: fine, no approval needed
• A restaurant dinner with a client to discuss their affairs: fine, keep the receipt, record if over £50 per head
• An expensive restaurant or sporting event with a potential client you are pitching to: requires prior approval
• Any entertainment funded by a supplier or referral partner: always record, and consider whether it could affect your objectivity

4.4 The Gifts Register

We maintain a gifts and hospitality register. David Elliott reviews it quarterly. Entries should include: date, description of gift or hospitality, approximate value, who gave or received it, the business context, and whether approval was sought. The register is available for inspection by ICAEW or any quality review body.

5. Facilitation Payments

We do not make facilitation payments (small payments to speed up routine official processes). These are illegal under the Bribery Act 2010 regardless of local custom. If you are ever asked to make such a payment, refuse and report it immediately.

6. Political and Charitable Contributions

EBA Group Limited does not make political donations or contributions.

Charitable donations and sponsorships are permitted but must not be used as a disguised bribe. Before making a charitable donation connected to a client relationship (for example, sponsoring a client's charity event), consider whether the donation could be perceived as influencing a business decision. If in doubt, get approval from the partner not involved in the client relationship.

7. Referral Fees and Commissions

Any referral fee or commission arrangement must be disclosed in writing to the affected client before the referral is made. See Section 9 of our Terms of Business for the full policy on commissions. Hidden referral arrangements are a bribery risk and are prohibited.

8. Record Keeping

We maintain accurate financial records and do not allow off-book accounts. All payments must be properly authorised, documented and recorded. David Elliott reviews financial records monthly. Any unusual or unexplained payments will be investigated.

9. Reporting Concerns

9.1 Internal Reporting

If you suspect or witness bribery, report it immediately to:

• David Elliott (Founder & Managing Partner) — david@eba-group.co.uk
• Mike Scott (Senior Partner) — hello@eba-group.co.uk
• Jonathan Elliott (Business Development Director) — hello@eba-group.co.uk

9.2 If the Concern Involves a Senior Partner

If your concern is about David Elliott, Mike Scott or Jonathan Elliott, or if you feel unable to raise it internally for any reason, you may report directly to:

• ICAEW's ethics helpline: +44 (0)1908 248 250
• The firm's external accountant or legal adviser (details available from any team member)
• Crimestoppers (anonymous): 0800 555 111

9.3 Whistleblower Protection

You will not be penalised, dismissed or disadvantaged for raising a genuine concern in good faith, even if the concern turns out to be unfounded. This protection applies regardless of your seniority. Retaliation against whistleblowers is itself a disciplinary matter.

10. Consequences of Breach

Any breach of this policy will be treated as a serious disciplinary matter and may result in dismissal. A breach may also constitute a criminal offence, which we would be obliged to report to the relevant authorities.

We take a proportionate approach: an honest mistake or a borderline case reported proactively will be treated very differently from a deliberate attempt to conceal wrongdoing.

11. Training

All new team members receive anti-bribery training during induction, covering: what bribery looks like in a professional services context, how to use the gifts register, and how to report concerns.

We provide a refresher annually as part of our compliance training schedule. David Elliott maintains a record of who has completed training and when. If you have not received training or would like a refresher, speak to David.

12. Review

This policy is reviewed annually by David Elliott, Mike Scott and Jonathan Elliott. The next review is due by March 2027. Material changes will be communicated to all team members.

Last updated: April 2026