1. Our Position
Stacksolver UK Limited ("Stacksolver", "we", "us", "our") operates a strict zero-tolerance approach to bribery and corruption in any form. We are committed to acting professionally, fairly and with integrity in all business dealings and relationships, wherever we operate.
This statement is issued in accordance with the United Kingdom Bribery Act 2010 (the "Act"), which applies to all UK companies regardless of size and includes extraterritorial reach.
2. Scope
This statement applies to all directors and employees of Stacksolver UK Limited, all subcontractors, consultants, agents and other third parties acting on our behalf, and all business activities including procurement, sales, partnerships and government interactions.
We expect those with whom we contract to maintain equivalent standards.
3. The Six Offences We Prevent
We prohibit any conduct that could constitute, or could reasonably be perceived to constitute:
- Active bribery — offering, promising or giving a financial or other advantage to influence improperly the conduct of another person.
- Passive bribery — requesting, agreeing to receive or accepting a financial or other advantage in exchange for performing a relevant function improperly.
- Bribery of foreign public officials (Section 6 of the Act) to obtain or retain business or business advantage.
- Failure to prevent bribery by associated persons (Section 7 of the Act) — the corporate offence we actively guard against.
- Facilitation payments of any kind, regardless of local custom or perceived urgency.
- Kickbacks in any form.
4. Gifts, Hospitality and Entertainment
Reasonable and proportionate gifts and hospitality given or received in the normal course of business are acceptable, provided they are not made with the intention of influencing any decision improperly, are not excessive in value, are appropriate to the circumstances and would not embarrass us or the recipient if disclosed, and are recorded transparently in our books.
We will decline or return any gift or hospitality that does not meet these criteria. We will not offer or accept any payment in cash equivalent.
5. Charitable and Political Contributions
Stacksolver does not make political donations of any kind. Charitable contributions, where made, are documented and reviewed to ensure they are not used as a means of improperly influencing any decision-maker.
6. Subcontractor and Supplier Due Diligence
Before engaging a subcontractor, supplier or other third party in a position to influence our business outcomes, we conduct proportionate due diligence. Our standard subcontractor and supplier agreements include obligations to comply with all applicable anti-bribery and anti-corruption laws.
7. Reporting and Speak-Up
Any director, employee, contractor, supplier, client or member of the public who suspects a breach of this statement is encouraged to report it confidentially to office@stacksolveruk.com, marking the message clearly as confidential.
Reports are handled in accordance with our Whistleblowing Policy. We will not tolerate retaliation against any individual who, in good faith, raises a concern.
8. Training and Communication
All directors and employees receive briefing on this statement on joining and at least annually thereafter. Subcontractors are made aware of our position through onboarding documentation and contractual clauses.
9. Governance
Responsibility for compliance with this statement sits with the Directors of Stacksolver UK Limited. The board reviews this statement at least every three years, or sooner if relevant law or business circumstances change.