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Anti‑Bribery, Gifts and Hospitality Policy

1. Our Commitment

We Dig Media Ltd is committed to operating responsibly, ethically, and with integrity in all areas of our work.

This policy forms part of our wider approach to good governance, responsible business practices, and compliance, alongside our:

  • Privacy Policy
  • Environment and Social Responsibility Policy (including Modern Slavery and Human Trafficking Statement)
  • Information Security Policy

We Dig Media Ltd has a zero‑tolerance approach to bribery and corruption in any form.

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2. Purpose of This Policy

The purpose of this policy is to:

  • Prevent bribery and corruption within our business activities
  • Ensure compliance with the UK Bribery Act 2010
  • Support ethical decision‑making and responsible business relationships
  • Protect the reputation of We Dig Media Ltd, our clients, and partners

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3. Scope

This policy applies to:

  • Directors
  • Employees
  • Freelancers, contractors, and consultants
  • Anyone acting on behalf of We Dig Media Ltd

We expect our business partners and suppliers to uphold similar standards of integrity.

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4. Legal and Ethical Framework

This policy reflects the requirements of the UK Bribery Act 2010, which applies to all UK businesses regardless of size.

Consistent with our other policies, We Dig Media Ltd takes a proportionate, risk‑based approach to compliance, appropriate to the scale and nature of our operations.

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5. What Is Bribery?

Bribery is offering, giving, requesting, or accepting anything of value to improperly influence a business decision or gain an unfair advantage.

This may include:

  • Cash or cash equivalents
  • Gifts, hospitality, or entertainment
  • Preferential treatment or inducements
  • Facilitation payments (which are illegal under UK law)

Bribery may occur directly or indirectly through third parties.

 

6. Gifts and Hospitality – Guiding Principles

Gifts and hospitality must:

  • Be reasonable, proportionate, and infrequent
  • Be appropriate to the business context
  • Never influence, or appear to influence, decisions
  • Never be offered or accepted in exchange for favourable treatment

Our approach mirrors the principles used in our Information Security and Sustainability policies: if something does not feel appropriate, it should not be accepted or offered.

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7. Accepting Gifts and Hospitality

7.1 What May Be Acceptable

The following may be acceptable where appropriate:

  • Low‑value promotional or branded items
  • Modest hospitality such as coffee, lunch, or refreshments
  • Event invitations linked to genuine business discussions or networking

As a general guideline, gifts or hospitality should not exceed £50 in value.

7.2 What Is Not Acceptable

We will not accept:

  • Cash or cash equivalents (including vouchers or gift cards)
  • Gifts or hospitality during pitching, tendering, or contract negotiations
  • Repeated gifts from the same individual or organisation
  • Any item or invitation that could reasonably be seen as influencing a decision

If refusing a gift would cause offence, it must be discussed with a Director, who will determine appropriate next steps.

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8. Offering Gifts and Hospitality

We Dig Media Ltd may offer modest gifts or hospitality where:

  • It supports legitimate professional relationships
  • It is proportionate and aligned with our values
  • It complies with the recipient’s own policies

Lavish, excessive, or inappropriate gifts or hospitality must never be offered.

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9. Conflicts of Interest

Gifts and hospitality can create conflicts of interest.
Anyone who becomes aware of a real or perceived conflict must:

  • Declare it promptly to a Director
  • Remove themselves from related decision‑making where appropriate

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10. Reporting Concerns

Any concerns relating to bribery, corruption, or inappropriate behaviour should be raised promptly with:

  • A Director of We Dig Media Ltd

Consistent with our broader approach to ethical and responsible conduct, concerns may be raised without fear of negative consequences when done in good faith.

11. Breaches of This Policy

Breaches of this policy may result in:

  • Disciplinary action
  • Termination of contracts or engagements
  • Reporting to relevant authorities where legally required

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12. Review

This policy is reviewed periodically to ensure it remains appropriate, effective, and consistent with our other policies and business practices.

Approved by: Directors of We Dig Media Ltd
Date: __01/04/26_
Next Review Date: ____01/04/28____