Anti-Bribery and Anti-Corruption Statement

1. Purpose

This policy sets out how Knowledge Exchange Group prevents bribery and corruption in all its business dealings. We are committed to acting honestly and ethically, in full compliance with the UK Bribery Act 2010 and all other applicable anti-corruption laws, and we adopt a zero-tolerance approach across the business.

2. Scope

This applies to:

• All directors, employees, freelancers, contractors, and temporary workers
• All suppliers, agents, and business partners acting on our behalf
• All business dealings, gifts, hospitality, and payments, in the UK and overseas

3. Our Commitments

We commit to the following:

• We do not offer, give, solicit, or accept bribes, kickbacks, or other improper payments or benefits, whether directly or through third parties
• We do not make facilitation payments to expedite routine government or administrative action
• We maintain accurate financial records and internal controls to prevent and detect bribery or corruption
• We carry out proportionate due diligence on suppliers, agents, and business partners

4. Gifts, Hospitality and Facilitation Payments

Gifts and hospitality offered or received in the course of business must be reasonable, proportionate, and transparent.

Rule: Gifts or hospitality must never be given or accepted with the intention of influencing a business decision, and facilitation payments of any kind are strictly prohibited.

5. Expectations of Suppliers and Business Partners

We expect all suppliers, contractors, and business partners to uphold the same standards set out in this policy and to comply with the Bribery Act 2010 in their dealings with us and on our behalf.

Rule: Any breach of this policy by a supplier or business partner may result in termination of the business relationship.

6. Prohibited Actions

Employees and associated persons must NOT:

• Offer, promise, or give any bribe, kickback, or improper benefit to any person
• Request or accept any bribe, kickback, or improper benefit from any person
• Make or authorise any facilitation payment
• Use a third party to do anything prohibited under this policy

7. Reporting Concerns

Any concerns regarding suspected bribery or corruption should be raised as soon as possible.

Rule: Employees, suppliers, and business partners may report concerns in confidence and without fear of retaliation.

8. Training, Access and Governance

• New starters, freelancers, and relevant suppliers will receive guidance on this policy
• This policy will be reviewed at least annually, or sooner if the law changes

9. Policy Enforcement

Breaches of this policy may result in:

• Disciplinary action, up to and including dismissal, for employees
• Termination of contract for suppliers, agents, or business partners
• Reporting to the relevant authorities where required by law

10. Questions or Approvals

Any concerns regarding suspected bribery or corruption should be reported to Alice Catterall

Alice Catterall
Managing Director
Knowledge Exchange Group Ltd
Date: January 10th 2026