1. Policy Statement
SpeedLink Transport Limited is committed to conducting its business honestly, ethically and with integrity.
We have a zero-tolerance approach to bribery and corruption and are committed to complying with all applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010.
SpeedLink will not offer, give, request, receive or accept bribes, kickbacks, facilitation payments or other improper advantages, either directly or through another person or organisation.
We expect the same standards from our employees, contractors, subcontractors, agents, suppliers, overseas representatives and other business partners.
This policy establishes the principles and procedures designed to reduce the risk of bribery and corruption within SpeedLink's operations and supply chain.
2. Scope
This policy applies to all persons working for or on behalf of SpeedLink Transport Limited, including:
- directors and officers;
- employees;
- temporary and agency workers;
- consultants;
- contractors and subcontractors;
- owner-drivers and transport providers;
- agents and representatives;
- overseas logistics and service partners; and
- any other person or organisation performing services for or on behalf of SpeedLink.
We also expect suppliers, customers, professional advisers and other organisations with which we conduct business to operate lawfully and ethically.
The principles within this policy apply to SpeedLink's activities in the United Kingdom and internationally.
3. What is Bribery?
Bribery involves offering, promising, giving, requesting, agreeing to receive or accepting a financial or other advantage with the intention of inducing or rewarding improper behaviour.
A bribe does not need to involve cash.
Examples may include:
- cash payments;
- gifts;
- excessive hospitality;
- commissions or secret payments;
- kickbacks;
- preferential treatment;
- free services;
- employment opportunities;
- travel or accommodation;
- charitable or political contributions;
- discounts or other commercial advantages; and
- any other benefit intended to improperly influence a decision.
It is irrelevant whether the bribe is offered directly or through a third party.
A bribe does not have to be successful for improper conduct to constitute a serious concern.
4. The Bribery Act 2010
The Bribery Act 2010 establishes several key offences, including:
- offering, promising or giving a bribe;
- requesting, agreeing to receive or accepting a bribe;
- bribing a foreign public official; and
- failure by a commercial organisation to prevent bribery by persons associated with it.
For the purposes of the legislation, an associated person may include an employee, agent, intermediary, contractor or other person performing services for or on behalf of an organisation.
SpeedLink therefore recognises that anti-bribery controls need to extend beyond its direct employees and into relevant parts of its supply chain and international partner network.
5. Our Zero-Tolerance Approach
No person working for or on behalf of SpeedLink may:
- offer, promise or provide a bribe;
- request, accept or agree to receive a bribe;
- provide a financial or other advantage intended to improperly influence another person;
- make an unofficial payment to obtain or accelerate a routine service;
- provide an inappropriate payment or benefit to a government or public official;
- use an agent, subcontractor or other intermediary to make a payment that SpeedLink could not legitimately make itself;
- conceal an improper payment within an invoice, expense claim or other accounting record; or
- retaliate against a person who raises a genuine concern regarding suspected bribery or corruption.
This prohibition applies regardless of the value of the proposed payment or advantage.
6. Risk Assessment
SpeedLink operates within the international transport and logistics industry and recognises that bribery and corruption risks can vary according to the nature of a transaction, the country involved and the third parties engaged.
Potential areas of increased risk may include:
- international customs and border procedures;
- overseas agents and representatives;
- interactions with public officials;
- airport and port operations;
- licences, permits and regulatory approvals;
- subcontracted transportation;
- procurement and supplier selection;
- high-value or unusual commissions;
- urgent or time-critical shipments;
- cash payment requests;
- payments to unfamiliar third parties;
- countries with higher recognised levels of corruption risk; and
- requests for unofficial payments to accelerate routine procedures.
SpeedLink will seek to apply proportionate controls according to the level of risk involved.
7. Facilitation Payments
SpeedLink prohibits facilitation payments.
Facilitation payments are unofficial payments made to public officials or other individuals to secure or accelerate the performance of a routine action to which the payer is already entitled.
Examples could include an unofficial payment requested to:
- accelerate customs clearance;
- obtain routine documentation;
- release a shipment;
- obtain an inspection;
- secure access to an airport or cargo facility; or
- accelerate another administrative process.
Such payments must not be made simply because they are customary or expected within a particular country.
If an employee or representative is asked to make a facilitation payment, the request should be refused wherever it is safe and practical to do so and reported to a Director of SpeedLink as soon as possible.
Where a payment is demanded because of an immediate and credible threat to an individual's health or personal safety, personal safety must take priority. Any such incident and payment must be reported to a Director as soon as reasonably possible and accurately recorded.
8. Gifts and Hospitality
SpeedLink recognises that reasonable and proportionate business hospitality can be a legitimate part of maintaining professional relationships.
Gifts or hospitality must never be offered or accepted where their purpose, or apparent purpose, is to improperly influence a business decision.
Any gift or hospitality must be:
- reasonable and proportionate;
- appropriate to the circumstances;
- given openly rather than secretly;
- permitted by applicable law;
- consistent with normal legitimate business practice; and
- incapable of reasonably being interpreted as a bribe or improper inducement.
Particular care must be taken where gifts or hospitality involve public officials, customs personnel, regulatory officials or individuals involved in awarding contracts or making procurement decisions.
Cash gifts or cash equivalents must not be offered or accepted.
Where there is uncertainty about whether a gift or hospitality is appropriate, approval should be obtained from a Director before proceeding.
9. Public Officials
Interactions with government and public officials may present an increased bribery risk.
For the purposes of this policy, public officials may include employees or representatives of:
- national or local governments;
- customs and border authorities;
- government departments;
- regulatory bodies;
- publicly controlled organisations;
- law enforcement authorities;
- state-owned or state-controlled enterprises; and
- international public organisations.
SpeedLink employees and representatives must never offer a payment, gift, benefit or other advantage to a public official with the intention of influencing that person in their official capacity or obtaining an improper business advantage.
Any unusual request for payment, hospitality or another benefit involving a public official should be referred to a Director.
10. Agents, Subcontractors and Business Partners
SpeedLink may work with transport providers, freight organisations, overseas agents, customs specialists, airlines, delivery companies and other third parties.
We recognise that SpeedLink may face legal and reputational risk from the conduct of persons performing services on its behalf.
Where appropriate and proportionate, SpeedLink may therefore:
- establish the identity and credentials of a prospective business partner;
- investigate the reputation and trading history of an organisation;
- consider the corruption risk associated with the country and service concerned;
- establish the commercial reason for using an intermediary;
- assess whether proposed fees or commissions appear reasonable;
- require compliance with applicable anti-bribery legislation;
- include appropriate anti-bribery provisions within commercial arrangements;
- require clarification of unusual payment instructions;
- refuse payments to unrelated third-party bank accounts; and
- terminate relationships where serious bribery or corruption concerns arise.
Employees must not deliberately ignore warning signs suggesting that an agent, supplier or other business partner may be acting improperly.
11. Red Flags
Examples of circumstances that may require further investigation include:
- a third party requesting payment in cash without a legitimate commercial reason;
- payment being requested to a personal or unrelated bank account;
- unusually high commissions or service fees;
- unexplained additional charges;
- invoices that do not clearly describe the services supplied;
- requests to incorrectly describe services on documentation;
- a supplier refusing to disclose who owns or controls the organisation;
- an agent claiming to have a special relationship with a public official;
- a request for an unofficial customs or clearance payment;
- excessive gifts or hospitality;
- pressure to make a payment urgently without documentation;
- a third party requesting payment in a country unrelated to the transaction;
- requests to backdate or falsify documents; or
- unexplained reluctance to enter into a written commercial agreement.
The presence of a red flag does not automatically establish wrongdoing but should not be ignored.
12. Charitable and Political Contributions
SpeedLink supports legitimate charitable and community initiatives where appropriate.
Charitable donations must never be made as a means of obtaining an improper business advantage.
Where a donation is connected to an existing or prospective customer, supplier, public official or commercial decision, additional care should be taken to ensure that the contribution is legitimate and cannot reasonably be considered an inducement.
Political contributions must not be made on behalf of SpeedLink without prior approval from the Board of Directors and must never be used to obtain an improper commercial advantage.
13. Conflicts of Interest
Employees and representatives should avoid situations in which personal interests could improperly influence, or appear to influence, decisions made on behalf of SpeedLink.
Potential conflicts may include:
- financial interests in suppliers or customers;
- close personal or family relationships with persons involved in procurement decisions;
- outside employment or commercial activities;
- personal benefits obtained through SpeedLink's commercial relationships; or
- involvement in selecting a supplier where the individual has a personal interest in that supplier.
Actual or potential conflicts of interest should be disclosed to a Director so that they can be appropriately managed.
14. Books, Records and Payments
SpeedLink is committed to maintaining accurate business and financial records.
Payments must be properly authorised, accurately documented and supported by appropriate commercial records.
Employees and representatives must not:
- create false or misleading invoices;
- misdescribe the purpose of a payment;
- create undisclosed accounts or funds;
- deliberately conceal the recipient of a payment;
- falsify expense claims;
- divide payments to avoid approval controls; or
- otherwise manipulate company records to conceal improper activity.
All expenses relating to gifts, hospitality, travel or payments to third parties must accurately state their purpose.
15. Reporting Concerns
Anyone working for or on behalf of SpeedLink is encouraged to report concerns about suspected bribery, corruption or other unethical behaviour.
Concerns should normally be reported to:
The Managing Director or another Director of SpeedLink Transport Limited.
Reports will be taken seriously and handled as confidentially as reasonably possible.
No employee should suffer dismissal, disciplinary action or other detrimental treatment for raising a genuine concern in good faith, even where an investigation subsequently determines that no wrongdoing occurred.
Knowingly making a false or malicious allegation is not protected by this provision.
16. What to Do if You Are Offered a Bribe
If an employee, contractor or representative is offered a bribe or improper payment, they should:
- Refuse the offer.
- Avoid making commitments to the person making the offer.
- Make an accurate record of what occurred.
- Retain any relevant correspondence or documentation.
- Report the incident promptly to a Director.
Employees should not attempt to conduct their own investigation where this could interfere with evidence or place themselves or another individual at risk.
17. Breaches of this Policy
Breaches of anti-bribery legislation can expose both individuals and organisations to serious criminal, financial and reputational consequences.
Any employee found to have breached this policy may face disciplinary action, which could include dismissal where appropriate.
SpeedLink may suspend or terminate relationships with contractors, agents, suppliers or other business partners that engage in bribery, corruption or serious breaches of this policy.
Where criminal conduct is suspected, SpeedLink reserves the right to refer the matter to the relevant authorities.
18. Training and Awareness
SpeedLink will seek to ensure that employees whose roles expose them to meaningful bribery or corruption risk are aware of this policy and understand their responsibilities.
Particular attention may be given to personnel involved in:
- procurement;
- supplier appointments;
- international operations;
- customs and border processes;
- overseas agents;
- financial approvals; and
- contract negotiation.
Training and awareness measures will be proportionate to the nature and level of risk facing the business.
19. Monitoring and Review
SpeedLink recognises that bribery risks may change as the company, its markets and its international supply chain develop.
The effectiveness of this policy will therefore be periodically reviewed.
The review may take into consideration:
- changes to legislation and regulatory guidance;
- new countries or markets;
- new agents or significant suppliers;
- changes to SpeedLink's business activities;
- concerns or incidents reported;
- findings arising from supplier due diligence;
- changes to identified bribery risks; and
- opportunities to strengthen internal controls.
Where weaknesses are identified, SpeedLink will seek to implement proportionate improvements.
20. Responsibilities
The Board of Directors has overall responsibility for ensuring that SpeedLink maintains an appropriate approach to bribery and corruption.
Management is responsible for promoting this policy and applying appropriate controls within areas under their supervision.
Employees and persons working on behalf of SpeedLink are responsible for:
- reading and understanding this policy;
- acting honestly and ethically;
- complying with relevant procedures;
- remaining alert to potential bribery risks; and
- reporting genuine concerns.
Prevention of bribery and corruption is the responsibility of everyone working for or on behalf of SpeedLink.
21. Our Continuing Commitment
SpeedLink Transport Limited is committed to maintaining high standards of integrity in all areas of its business.
We recognise that effective anti-bribery procedures should be proportionate to the risks faced by the organisation and should develop as the business changes.
We will continue to assess relevant risks, undertake appropriate due diligence, communicate our expectations to employees and business partners, and review the effectiveness of our controls.
SpeedLink will not knowingly enter into or continue a business relationship where bribery or corruption is considered an acceptable way of doing business.
22. Approval
This Anti-Bribery & Corruption Policy has been approved by the Board of Directors of SpeedLink Transport Limited.
David McMillen
Managing Director
SpeedLink Transport Limited
Date: January 1, 2026