Anti-bribery and corruption policy

Our Commitment

We are committed to conducting business with integrity, transparency and professionalism. We maintain a zero-tolerance approach to bribery and corruption and are committed to complying with all applicable anti-bribery laws, including the U.K. Bribery Act 2010.

Policy

We do not offer, promise, give, request or accept bribes or other improper inducements in order to obtain or retain business, secure an unfair advantage, or influence any business decision.

This commitment applies to all business activities, relationships and transactions undertaken by us.

Where we recommend the products or services of a third party to our clients, we will always do so based solely on our assessment of the client’s business interests. If we have a commercial relationship with a supplier we recommend, we will always make that known as part of our recommendation.

Gifts and Hospitality

Reasonable and proportionate business hospitality may be offered or accepted where it is lawful, transparent and appropriate to our relationship with a client. Gifts, hospitality or expenses will never be used to improperly influence a business decision or create an obligation.

Third Parties

We seek to work with third parties who share our commitment to ethical business practices. We will not knowingly engage with any party involved in bribery, corruption or other unlawful conduct.

Reporting Concerns

Any concerns regarding actual or suspected bribery, corruption or unethical conduct should be reported to us as soon as possible. All concerns will be taken seriously and investigated appropriately.

Responsibility

Responsibility for implementing and maintaining this policy rests with the directors of Stonebeck Ltd. The policy will be reviewed periodically to ensure it remains effective and appropriate for the business.

Last reviewed: June 2026