Our position
Bubble Fresh (Bubblefresh Limited, company number 12691029) operates a zero-tolerance approach to bribery and corruption. We are committed to conducting our business honestly, ethically, and in full compliance with the Bribery Act 2010. This policy applies to all employees, contractors, agency workers, and anyone acting on behalf of Bubble Fresh, including any future subcontractors (see our Subcontractor Policy). It covers all of our business activities, including our council partnerships with Northamptonshire Council, Milton Keynes Council, Norfolk County Council, and Norwich City Council. Our approach is guided by the six principles set out in the Ministry of Justice guidance on the Bribery Act 2010: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.
The Bribery Act 2010
The Bribery Act 2010 creates four criminal offences: offering, promising, or giving a bribe (Section 1); requesting, agreeing to receive, or accepting a bribe (Section 2); bribing a foreign public official (Section 6); and failure by a commercial organisation to prevent bribery by persons associated with it (Section 7). Individuals found guilty of bribery offences under Sections 1, 2, or 6 face up to 10 years in prison, an unlimited fine, or both. An organisation found guilty under Section 7 faces an unlimited fine. Under Section 7, a commercial organisation can be held liable for failing to prevent bribery by persons associated with it, unless the organisation can show that it had adequate procedures in place to prevent bribery. This policy, together with the procedures described in it, forms part of our adequate procedures defence under Section 7.
What constitutes bribery
Bribery is offering, giving, receiving, or soliciting something of value to influence a business decision or gain an improper advantage. This includes cash payments, excessive gifts or hospitality, favours, kickbacks, or any other inducement intended to influence a decision improperly. It does not matter whether the bribe is offered directly or through a third party. A bribe does not have to succeed to be a criminal offence — the act of offering or requesting one is enough.
Facilitation payments
Facilitation payments are small, unofficial payments made to speed up routine actions, such as processing permits or paperwork. They are illegal under the Bribery Act 2010 and we prohibit them in all circumstances, regardless of local custom or practice. If anyone asks you to make a facilitation payment, refuse and report it immediately to management.
Bribery risks in our business
We have assessed the bribery risks specific to our business. As a company that works closely with local councils and public sector bodies, our main areas of bribery risk include: securing or retaining council contracts and partnerships, procurement of supplies (cleaning products, equipment, waste disposal services), relationships with council officers and elected members, gifts or hospitality offered by or to suppliers, clients, or public officials, and the use of any future subcontractors or agents. We review our bribery risk assessment annually and update it whenever there is a significant change to our business or the way we operate. The risk assessment is documented, approved by the Director, and available for review by council partners on request.
Gifts and hospitality
Do not offer or accept gifts, hospitality, or other benefits that could be seen as an attempt to influence business decisions. Modest gifts of token value up to £25 (such as a thank-you card or small box of chocolates) may be accepted but must be reported to management within 5 working days. Decline and report any offers of gifts or hospitality from clients, council officers, or suppliers that could be seen as excessive or intended to influence a decision. You must never offer gifts or hospitality to any council officer or elected member without the prior written approval of the Director. All gifts and hospitality offered, whether accepted or declined, are recorded in a gifts and hospitality register maintained by management. The register is reviewed quarterly by the Director and is available for inspection by council partners or auditors on request.
Public sector contracts
As a company that works with local councils, we are particularly alert to the risks of bribery in the public sector. Council officers are required under Section 117 of the Local Government Act 1972 to declare any pecuniary interest in council contracts. We will never offer any inducement to council officers, elected members, or anyone involved in a procurement or commissioning decision in order to secure or retain contracts. We win and retain our council partnerships through the quality of our work, not through improper influence. We conduct all tender submissions and contract negotiations honestly and transparently. We comply with the procurement rules and codes of conduct set out by each of our council partners.
Political donations and contributions
Bubble Fresh does not make donations or contributions, whether financial or in kind, to any political party, political organisation, or individual politician. This applies to donations at local, national, and international level. No employee may make a political donation or contribution on behalf of Bubble Fresh.
Charitable donations and sponsorship
Any charitable donation or sponsorship made on behalf of Bubble Fresh must be approved in advance by the Director. We do not make charitable donations or sponsorship payments as a way to gain a business advantage or to influence a decision. We will not make donations to any organisation that is connected to a person involved in a commissioning or procurement decision affecting Bubble Fresh. All charitable donations and sponsorship are recorded in writing, including the amount, the recipient, the purpose, and the approval, and are available for review.
Conflicts of interest
You must declare any personal interest that could conflict, or could appear to conflict, with your duties at Bubble Fresh. This includes any financial interest in a supplier, any close personal relationship with a council officer or elected member involved in commissioning our services, or any outside employment or activity that could create a conflict. Declare conflicts of interest to the Director in writing as soon as you become aware of them. This is an ongoing duty — you must update your declaration whenever your circumstances change. We maintain a conflicts of interest register and review it annually. Where a conflict is identified, the Director will decide what steps are needed to manage it, which may include removing the person from any related decision-making.
Due diligence on third parties
Before entering into any new business relationship with a supplier, subcontractor, or agent, we carry out proportionate due diligence to assess bribery risk. This includes checking the third party's reputation, business history, and any known involvement in bribery or corruption, assessing the bribery risks associated with the country, sector, and nature of the relationship, and requiring the third party to confirm in writing that they comply with the Bribery Act 2010 or equivalent anti-bribery laws. We include anti-bribery clauses in our contracts with suppliers and subcontractors, including the right to terminate the contract if the third party is found to have been involved in bribery. We also monitor existing business relationships on an ongoing basis and repeat due diligence checks at contract renewal. For more detail on our vetting of subcontractors, see our Subcontractor Policy.
Record keeping
We keep accurate and up-to-date records of all financial transactions and business dealings. We do not create or maintain any off-the-books accounts, secret funds, or misleading records. Records that support our anti-bribery compliance include the gifts and hospitality register, the conflicts of interest register, the bribery risk assessment, due diligence records for third parties, training records (including attendance at anti-bribery training), and records of any reports or investigations under this policy. All records are maintained to a standard that would withstand regulatory scrutiny or audit. We retain these records for a minimum of 6 years and make them available for audit or inspection on request.
Reporting concerns
If you suspect bribery or corruption, whether by a colleague, a client, a council officer, or a supplier, report it immediately to the Director, Lance James, or through our Whistleblowing Policy. You can report by email at royeeckophnyopemrlxhtcdpqz@brvfuiswbyzlbxlilcayeoswfhkxryfbewdosksdhsdv.cxfcqpnojmn.lcxuhgwkxyd or by phone on 01933 213045. If you use Relay UK, dial 18001 then 01933 213045. You can also report anonymously. You do not need to have proof before reporting — a genuine suspicion is enough. We take all good-faith reports seriously and investigate them promptly. We protect the reporter from any retaliation, in line with the protections set out in our Whistleblowing Policy and the Public Interest Disclosure Act 1998. If you are not comfortable raising the concern internally, you can report suspected bribery to the Serious Fraud Office (SFO), the National Crime Agency (NCA), or the police.
Investigation of reports
We investigate all reports of suspected bribery or corruption promptly and thoroughly. The Director will lead or oversee any investigation, unless the report relates to the Director, in which case we will appoint an external adviser. We keep investigations confidential and conduct them fairly. We keep the person who raised the concern informed of the outcome where it is safe and appropriate to do so. If an investigation finds evidence of bribery, we will take the action set out in the Consequences section below and, where appropriate, report the matter to the relevant authorities.
Training
All employees receive anti-bribery awareness training as part of their induction before starting work. We provide a refresher training session at least once a year to make sure everyone understands their responsibilities under this policy and the Bribery Act 2010. We also provide additional training when there are changes to this policy or to relevant legislation. Training covers what bribery is, how to recognise it, the company's zero-tolerance position, the gifts and hospitality rules, how to report concerns, and the consequences of non-compliance. Training is delivered by the Director or a suitably qualified person. We record all training, including dates, content, and attendees, and keep records in line with our Training & Development Policy.
Consequences
We treat any breach of this policy as a serious matter. Any employee found to have been involved in bribery or corruption will face disciplinary action under our Disciplinary Procedure, up to and including dismissal for gross misconduct. Individuals involved in bribery may also face personal criminal prosecution under the Bribery Act 2010 and, if convicted, imprisonment, an unlimited fine, or both. Where appropriate, we will report the matter to the police, the Serious Fraud Office (SFO), or other relevant authorities. Any third party, supplier, or subcontractor found to have been involved in bribery will have their contract terminated immediately.
The Director's responsibilities
The Director, Lance James, has overall responsibility for this policy and for ensuring that Bubble Fresh maintains adequate procedures to prevent bribery. This includes approving and reviewing the bribery risk assessment, reviewing the gifts and hospitality register and conflicts of interest register, ensuring all employees receive anti-bribery training, overseeing the investigation of any reports of suspected bribery, and reporting to council partners on anti-bribery compliance when required. The Director's commitment to zero tolerance sets the tone from the top and is communicated to all employees.
Related policies
This policy should be read alongside our Whistleblowing Policy, which covers how to raise concerns about wrongdoing; our Code of Conduct, which sets out the standards of behaviour expected of all workers; our Subcontractor Policy, which covers our vetting and management of subcontractors; our Disciplinary Procedure, which sets out how we handle breaches of company policy; our Training & Development Policy, which covers how we deliver and record training including anti-bribery awareness; and our Privacy Policy, which explains how we handle personal data.
Contact us
If you have any questions about this policy, contact us on 01933 213045 or by post at Bubblefresh Limited, 6 Carnegie Street, Rushden, Northamptonshire, NN10 9SN. If you use Relay UK, dial 18001 then 01933 213045.
Changes to this policy
We may update this policy from time to time. Material changes include any change to the scope of the policy, the gifts and hospitality rules, the reporting process, or the consequences of non-compliance. Where we make material changes, we will notify all affected parties directly and provide updated training where needed. The current version of this policy is always available on our website and from management on request.
Review
The Director, Lance James, reviews this policy annually and whenever there is a significant change to our business, our council contracts, or relevant legislation. Last reviewed: February 2026. Next review due: February 2027.
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