This page was last updated on 24 February 2025
Approved By: Nick Tune, Chief Executive Officer
1. Purpose
Optimise-AI is committed to conducting business with integrity, transparency, and respect for human rights. This Anti-Slavery and Bribery Policy outlines our zero-tolerance approach to modern slavery, human trafficking, and bribery in all forms, ensuring compliance with the UK Bribery Act 2010 and the Modern Slavery Act 2015. We aim to uphold ethical standards across our operations, supply chain, and partnerships.
2. Scope
This policy applies to:
All employees, directors, officers, and temporary staff of Optimise-AI.
Third parties acting on our behalf, including suppliers, contractors, consultants, and business partners.
All business activities conducted in the UK and internationally.
3. Definitions
Bribery: Offering, promising, giving, accepting, or soliciting an advantage (financial or otherwise) as an inducement for improper performance of a function or activity.
Modern Slavery: Includes slavery, servitude, forced or compulsory labour, and human trafficking as defined by the Modern Slavery Act 2015.
Improper Performance: A breach of expectation that a function or activity is performed in good faith, impartially, or in accordance with a position of trust.
4. Policy Statements
4.1 Anti-Bribery
Optimise-AI prohibits all forms of bribery, including:
Offering, giving, or promising bribes to public officials or private individuals to secure business advantages.
Requesting, accepting, or agreeing to receive bribes.
Facilitation payments (small unofficial payments to expedite routine governmental actions), unless explicitly permitted by local law and approved in writing by the CEO.
Excessive gifts, hospitality, or entertainment that could influence, or appear to influence, business decisions.
Employees and associated persons must:
Act honestly and refrain from conduct that could breach the Bribery Act 2010.
Declare and record any gifts or hospitality offered or received exceeding £50 in value in the company’s Gifts and Hospitality Register.
Report any suspected bribery immediately (see Section 6).
4.2 Anti-Slavery
Optimise-AI rejects all forms of modern slavery and human trafficking. We will not:
Engage in, or tolerate, forced labour, child labour, or any exploitative practices in our operations.
Knowingly work with suppliers or partners who fail to uphold equivalent standards.
We commit to:
Ensuring fair working conditions for all employees, including compliance with the UK’s National Minimum Wage and Working Time Regulations.
Assessing and mitigating slavery risks in our supply chain, particularly with technology vendors and service providers.
5. Responsibilities
Leadership: The CEO and senior management are responsible for enforcing this policy, setting a tone of zero tolerance, and ensuring adequate resources for compliance.
Employees: All staff must read, understand, and comply with this policy, reporting violations promptly.
Suppliers: Third parties must adhere to equivalent anti-slavery and anti-bribery standards, verified through due diligence and contractual terms.
6. Reporting Violations (Whistleblowing)
Suspected breaches of this policy—whether bribery, slavery, or related misconduct—must be reported immediately to the CEO (Nick Tune, nick.tune@optimise-ai.com) or, if involving senior management, to an independent board member.
Optimise-AI guarantees no retaliation against whistleblowers acting in good faith. Anonymous reports can be submitted via a secure email (to be established) or in writing to our registered office: Optimise-AI, Cardiff University, Cardiff, Wales.
Reports will be investigated promptly, confidentially, and, where necessary, escalated to law enforcement.
7. Risk Management and Due Diligence
Internal: Annual training on bribery and slavery risks will be mandatory for all staff, starting in 2025.
Suppliers: We will conduct risk-based due diligence on suppliers, prioritizing high-risk regions or sectors (e.g., hardware manufacturing). Contracts will include clauses requiring compliance with this policy and the right to audit.
Monitoring: Regular audits of our operations and supply chain will assess compliance, with findings reported to the board.
8. Consequences of Non-Compliance
Employees: Breaches may result in disciplinary action, up to and including dismissal, and referral to authorities if criminal conduct is suspected.
Third Parties: Non-compliant suppliers or partners face contract termination and exclusion from future business.
Optimise-AI will cooperate fully with law enforcement in cases of illegal activity.
9. Compliance with UK Law
This policy meets the requirements of the Bribery Act 2010, covering active and passive bribery, bribery of foreign officials, and failure to prevent bribery (Section 7).
Under the Modern Slavery Act 2015, Optimise-AI will publish an annual Slavery and Human Trafficking Statement if our turnover exceeds £36 million, detailing our steps to eradicate slavery from our operations and supply chain. As an SME, we adopt these principles voluntarily to align with best practices.
10. Review and Updates
This policy will be reviewed annually or sooner if legislative changes or business needs arise. Updates will be communicated to all staff and relevant third parties.
11. Contact
For questions or clarification, contact:
Nick Tune, CEO
Email: nick.tune@optimise-ai.com
Address: OptimiseAI c/o Bevan & Buckland, Cardigan House, Swansea, SA7 9LA