Anti-Bribery and Anti-Corruption Policy

Global Exposure Ltd (“the Company”, “we”, “us”) is committed to conducting business fairly, honestly and openly, and with zero tolerance for bribery and corruption in any form. We are committed to acting professionally and with integrity in all our business dealings and relationships, wherever we operate, and to implementing and enforcing effective systems to counter bribery and corruption.

This policy is made in accordance with the Bribery Act 2010. Bribery is a criminal offence. Individuals found guilty can face imprisonment of up to ten years and an unlimited fine, and the Company can face an unlimited fine, exclusion from tendering for contracts and serious damage to its reputation. We therefore take our legal responsibilities very seriously.

This policy applies to all persons working for or on behalf of the Company at any level, including directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, freelancers, trainees, agency staff, agents, referral partners, resellers, or any other person providing services to or for us (together, “workers”).

It applies to our conduct with all third parties, including clients and prospective clients, suppliers, hosting and technology partners, advertising platforms, business brokers, introducers, professional advisers, public officials and public bodies.

A bribe is a financial or other advantage offered, promised, given, requested or accepted with the intention of inducing or rewarding the improper performance of a function or activity, or where acceptance of the advantage would itself be improper. Bribes can take many forms, including:

• cash, cash equivalents, vouchers or gifts;
• excessive hospitality, entertainment or travel;
• kickbacks, undisclosed commissions or inflated referral fees;
• political or charitable donations made to win business;
• offers of employment, work placements or contracts to connected persons;
• unwarranted discounts, rebates or free services.

Under the Bribery Act 2010 it is an offence to offer or pay a bribe, to request or receive a bribe, to bribe a foreign public official, and, for the Company, to fail to prevent bribery by a person associated with it.

No worker may:

• give, promise to give, or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
• accept a payment, gift or hospitality from a third party where it is known or suspected that it is offered with the expectation of obtaining a business advantage in return;
• give or accept a gift or hospitality during any commercial negotiation, tender or acquisition process, where it could be perceived as intended to influence the outcome;
• pay, offer or accept a “facilitation payment” or “kickback” of any kind – small unofficial payments made to secure or speed up a routine action are illegal under UK law;
• offer or pay undisclosed commissions or referral fees. All referral, introducer and partner commissions must be agreed in writing, disclosed where appropriate, and recorded accurately in the Company’s accounts;
• threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy.

This policy does not prohibit normal, appropriate and proportionate hospitality given or received in the ordinary course of business, such as modest meals, promotional items of low value, or attendance at industry or networking events. A gift or hospitality is acceptable only if all of the following apply:

• it is not made with the intention of influencing a decision, obtaining or retaining business, or securing an improper advantage;
• it complies with the law, is given in the Company’s name (not an individual’s), and does not include cash or a cash equivalent;
• it is appropriate in the circumstances, of a reasonable and proportionate value, and given openly, not secretly;
• it is not offered to or accepted from a public official or government body without prior approval from the Managing Director.

Any gift or hospitality given or received with an estimated value over £50 must be reported to the Managing Director and recorded in the Company’s gifts and hospitality register. If in doubt about whether a gift or invitation is acceptable, workers must seek guidance before giving or accepting it.

The Company does not make contributions to political parties. Charitable donations and sponsorships (including community and Chamber of Commerce activity) are permitted only where they are legal and ethical, are not made to secure a business advantage, and are approved in advance by the Managing Director and recorded accurately in the Company’s accounts.

The Company may be liable for bribery committed on its behalf by third parties. Accordingly:

• appropriate due diligence must be carried out before engaging agents, introducers, referral partners, resellers, subcontractors or other intermediaries;
• all such arrangements must be documented in writing, with remuneration that is proportionate to legitimate services actually provided;
• in any business acquisition, merger or investment activity, due diligence must consider bribery and corruption risk, and no payment or benefit may be offered to any individual to influence the conduct or outcome of a sale process;
• workers must terminate or escalate any relationship where a third party is known or reasonably suspected to be engaging in bribery.

We keep financial records and maintain appropriate internal controls evidencing the business reason for payments to third parties. All accounts, invoices, expenses claims and other documents relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts may be kept “off-book” to facilitate or conceal improper payments.

We keep financial records and maintain appropriate internal controls evidencing the business reason for payments to third parties. All accounts, invoices, expenses claims and other documents relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts may be kept “off-book” to facilitate or conceal improper payments.

Any worker who breaches this policy will face disciplinary action, which may result in dismissal for gross misconduct. The Company may terminate its relationship with any contractor, agent, partner or other third party who breaches this policy, and may report matters to the relevant authorities.

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations. The Managing Director has primary day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with queries about it, and auditing internal control systems to ensure they are effective in countering bribery and corruption.

Training on this policy forms part of the induction process for all new workers, and all existing workers will be reminded of its content periodically. This policy will be reviewed at least annually and updated as required. It does not form part of any employee’s contract of employment and may be amended at any time.

Approved by: Reece Hussain (Managing Director) on 1st of August 2026

Next review date: 1st August 2027