Anti Bribery Policy

Purpose

Zoocha is committed to conducting business ethically, honestly and with integrity in all of its activities and relationships.

The purpose of this policy is to establish Zoocha's approach to preventing bribery and corruption, ensuring compliance with applicable legal, regulatory and contractual obligations, including the UK Bribery Act 2010, and protecting the organisation, its employees, clients, suppliers and stakeholders from bribery-related risks.

Scope

This policy applies to:

All employees.
Contractors, consultants and temporary workers.
Directors and members of the Management Team.
Suppliers, partners, agents and other third parties acting on behalf of Zoocha where applicable.

The policy applies to all business activities, regardless of location, including interactions with clients, suppliers, government bodies, regulators, partners and other third parties.

Policy Statement

Zoocha operates a zero-tolerance approach to bribery and corruption.

No employee, contractor or representative of Zoocha may offer, promise, give, request, agree to receive or accept a bribe or other improper advantage for the purpose of obtaining, retaining or directing business, securing favourable treatment, influencing a decision or obtaining any improper personal, commercial or regulatory advantage.

Bribery and corruption risks shall be identified and managed through Zoocha's governance, risk management, supplier management, client engagement and due diligence processes where appropriate.

Prohibited Conduct

Zoocha strictly prohibits:

Bribery in any form.
Facilitation payments, except where an immediate threat to personal safety leaves no reasonable alternative.
Kickbacks or secret commissions.
Offering or accepting improper gifts, hospitality, benefits or incentives.
Improper political donations or contributions.
Concealing or disguising improper payments through third parties, charitable donations, sponsorships or other arrangements.
Any activity that could create the appearance of bribery, corruption or undue influence.

Gifts, Hospitality and Donations

Zoocha recognises that reasonable and proportionate gifts, hospitality and charitable activities may form part of legitimate business relationships.

However, such activities must never:

Influence, or appear to influence, a business decision.
Create a conflict of interest.
Breach applicable laws, regulations or contractual obligations.
Be offered or accepted in exchange for favourable treatment.
Be concealed or improperly recorded.

The detailed management of gifts, hospitality, charitable donations, approvals and associated record keeping is governed through Zoocha's supporting governance processes and registers.

Political donations shall not be made on behalf of Zoocha.

Reporting and Escalation

Any employee or representative who:

Becomes aware of suspected bribery or corruption;
Is offered a bribe;
Is asked to make an improper payment; or
Has concerns regarding conduct that may breach this policy

must report the matter as soon as reasonably practicable.

Concerns may be raised through:

A Line Manager.
A member of the Management Team.
The Whistleblowing Policy.
Other approved reporting channels.

Reports made in good faith will be treated seriously and investigated appropriately.

Roles and Responsibilities

Role	Responsibilities
Management Team	Provide governance oversight, promote an ethical culture and ensure appropriate anti-bribery controls are maintained.
Line Managers	Support awareness, provide guidance and escalate concerns where required.
Finance and Operational Management	Maintain accurate records, support financial transparency and ensure appropriate controls are followed.
All Personnel	Comply with this policy, avoid improper conduct, report concerns and complete required training and awareness activities.

Training and Awareness

Anti-bribery and anti-corruption awareness shall form part of Zoocha's onboarding and ongoing governance activities where appropriate.

Personnel must ensure they understand their responsibilities under this policy and seek guidance where uncertainty exists.

Compliance

Failure to comply with this policy may result in disciplinary action, termination of contractual arrangements, legal proceedings, regulatory action or other appropriate measures.

Zoocha will investigate suspected breaches and take appropriate corrective action where necessary.

Policy Review

This policy shall be reviewed in accordance with the Zoocha Document Management Policy and whenever significant legal, regulatory, organisational or governance changes occur.

Reviews should consider:

Changes in anti-bribery legislation.
Internal audit findings.
Supplier and third-party risks.
Reported concerns and investigations.
Lessons learned and continual improvement opportunities.

Last Updated on: 23/06/2026