Anti-Bribery and Corruption Policy

Introduction

QCD Holdings Ltd is committed to conducting its business with integrity, transparency, and fairness. We have a zero-tolerance approach to bribery and corruption and are committed to complying with all applicable anti-bribery and corruption laws, including the UK Bribery Act 2010.

Key Principles

  1. Prohibition of Bribery: We prohibit the offering, giving, receiving, or soliciting of any bribe, whether in the form of cash, gifts, hospitality, or any other benefit.

  2. Facilitation Payments: QCD Holdings Ltd does not make or accept facilitation payments, which are unofficial payments made to secure or expedite routine actions.

  3. Gifts and Hospitality: Any gifts or hospitality offered or received must be reasonable, proportionate, and transparently recorded. Lavish or excessive gifts and hospitality are strictly prohibited.

  4. Third-Party Relationships: We expect all third parties acting on our behalf, including suppliers, contractors, and agents, to comply with our anti-bribery and corruption principles.

  5. Conflict of Interest: Employees must avoid situations where personal interests could conflict with the interests of QCD Holdings Ltd. Any potential conflicts of interest must be disclosed to management.

Reporting and Compliance

Employees are required to report any suspected bribery or corruption to the Compliance Officer by email to info@qcd.holdings. Failure to comply with this policy may result in disciplinary action, including dismissal.

Review and Monitoring

This policy will be reviewed annually to ensure it remains relevant and effective in preventing bribery and corruption.