01
Zero tolerance
We take a zero-tolerance approach to bribery and corruption. No exceptions and no thresholds, no matter how small the favour, or how senior the person offering it.
Company › Statement
Zero tolerance.
No exceptions.
How we prevent bribery and corruption: compliant with the UK Bribery Act 2010, enforced across every business relationship.
Conducted honestly and ethically, always.
A baseline we hold ourselves to across every jurisdiction we operate in.
This statement outlines Cloudax Ltd's commitment to preventing bribery and corruption in all our business dealings, and to maintaining the highest standards of integrity in accordance with the UK Bribery Act 2010.
Cloudax Ltd is committed to conducting business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.
We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, the UK Bribery Act 2010 included.
Four principles behind the policy.
02
Full compliance
We uphold all laws relevant to countering bribery and corruption in every jurisdiction in which we operate, including the UK Bribery Act 2010.
03
Proactive due diligence
We conduct appropriate due diligence on all business relationships to ensure partners share our commitment to ethical business practice before we engage them.
04
Protected reporting
We encourage employees, partners and third parties to raise concerns, and we protect anyone who reports in good faith from retaliation.
Five commitments. Enforced.
It is our policy to conduct all business honestly and ethically. Zero tolerance, every relationship.
Prohibit any form of bribery
No bribery or corruption by our employees, contractors, or business partners: anywhere, for any reason.
Transparent business relationships
Ensure all business relationships are conducted transparently and ethically, with clear documentation.
Robust due diligence
Implement rigorous due diligence procedures across every business relationship we enter.
Clear guidance and training
Provide clear guidance and regular training to all employees on anti-bribery matters.
Open reporting channels
Encourage the reporting of any concerns about potential bribery or corruption, and protect those who come forward.
Non-compliance is career-ending, and criminal.
Any employee found to be in breach of this policy may face disciplinary action, including dismissal. Bribery is a criminal offence that can result in significant penalties for both individuals and organisations, including unlimited fines and imprisonment. We also do not make facilitation payments of any kind, and expect our business partners to hold the same line.
Zero
Tolerance for bribery
Unlimited
Potential individual fines
10 yrs
Maximum prison sentence
No
Facilitation payments ever
The specifics: gifts, due diligence, reporting.
How the policy operates across different touch-points in the business.
What counts as bribery
Offering or giving
Offering, promising or giving any financial or other advantage intended to induce or reward improper behaviour.
Requesting or receiving
Requesting, agreeing to receive or accepting any such advantage.
Foreign public officials
Bribing a foreign public official, covered specifically under the UK Bribery Act 2010.
Failure to prevent
Failing to prevent bribery by people acting on our behalf: a statutory offence for which the organisation is liable.
Gifts & hospitality
Modest & appropriate
Of modest value and appropriate in the circumstances (no luxury trips, no extravagant gifts).
Open & transparent
Given or received openly, with no suggestion of secrecy, and properly recorded in line with our procedures.
Never to influence
Not offered or received with the intention of influencing business decisions.
Cash is prohibited
Gifts of cash or cash equivalents are strictly prohibited under all circumstances.
Due diligence
Bribery risk assessment
Assessing bribery and corruption risks associated with potential business partners before engagement.
Contractual commitments
Requiring contractual commitments to anti-bribery compliance in our standard agreements.
Ongoing monitoring
Regular monitoring and review of existing business relationships, not a one-off onboarding check.
Decisive action
Taking appropriate action (including termination) if concerns arise and cannot be satisfactorily resolved.
Reporting concerns
Direct reporting
Direct channel to management for raising concerns in the normal course.
Anonymous whistleblowing
Anonymous reporting through our whistleblowing procedures, with no fear of attribution.
Good-faith protection
Full protection for those who report concerns in good faith: no retaliation, ever.
Prompt investigation
Prompt and thorough investigation of all reported concerns, with action taken where warranted.
Trained, reviewed, approved.
Training & communication
Regular training for all employees covering what constitutes bribery, high-risk situations, how to respond appropriately, and the personal and organisational consequences of non-compliance.
Monitoring & review
Regular risk assessments, policy reviews, compliance monitoring, and investigation of any issues that arise. What we measure, we manage.
Board approval
This statement has been approved by the Board of Directors and is reviewed annually to ensure it remains current and effective.
Speak up. We'll listen.
We encourage all employees, business partners and third parties to raise concerns about potential bribery or corruption. Reports made in good faith are protected. There will be no retaliation, and all reports will be investigated promptly and thoroughly.
Approved by the Board of Directors. Cloudax Ltd is registered in England & Wales, Company No. 14717183.
Last updated: 31st December 2025
Questions or concerns?
If you have questions about this policy, or want to report a concern in confidence, get in touch.
Cloudax Ltd · Registered in England & Wales, Company No. 14717183
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