Beacon Telematics Ltd – Anti-Bribery and Corruption Policy

1. Policy Statement

Beacon Telematics Ltd (“the Company”) is committed to conducting all business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships wherever we operate.

We will implement and enforce effective systems to counter bribery and uphold all laws relevant to anti-bribery and corruption, including the UK Bribery Act 2010.

Bribery and corruption are criminal offences punishable by up to ten years’ imprisonment and/or an unlimited fine. If our Company is found to have taken part in corrupt activities, we could also face serious reputational damage and exclusion from public contracts. We therefore take our legal and ethical responsibilities very seriously.

2. Purpose

The purpose of this policy is to:

Define what constitutes bribery and corruption.

Set out the responsibilities of Beacon Telematics Ltd staff and associated persons in observing and upholding our stance against bribery.

Provide information and guidance to all employees and business partners to recognise and deal with bribery and corruption issues.

3. Scope

This policy applies to all individuals working at all levels and grades within Beacon Telematics Ltd, including:

Directors, officers, and employees (permanent, fixed-term, or temporary)

Contractors, consultants, trainees, and agents

Business partners, representatives, or any third party acting on our behalf

The policy also applies to interactions with all external parties, including clients, suppliers, agents, government officials, and any other persons connected with our business.

4. Definition of Bribery

Bribery is the offering, promising, giving, requesting, or accepting of any advantage or item of value (whether financial or otherwise) to influence the actions of another person in the performance of their official duties or to gain any improper business advantage.

Examples include:

Offering or accepting cash or gifts as an inducement for preferential treatment.

Providing lavish hospitality to influence decision-making.

Making “facilitation payments” to speed up routine government actions.

5. What Is Not Acceptable

Giving or accepting gifts or hospitality that could be perceived to influence a business decision.

Offering anything of value to public officials, politicians, or clients with the intention to gain an improper advantage.

Making facilitation payments or unofficial payments to secure services.

Ignoring or failing to report any suspected bribery or corruption.

Reasonable and proportionate hospitality or promotional expenditure intended to build legitimate business relationships is acceptable, provided it is transparent and properly recorded.

6. Responsibilities

All employees and associated persons must comply with this policy and ensure their actions are transparent, honest, and defensible.

Managers and supervisors are responsible for communicating this policy, promoting awareness, and ensuring compliance within their teams.

Any employee who suspects bribery or corruption must report it immediately to their line manager or the Managing Director.

7. Gifts and Hospitality

Gifts or hospitality must always be:

Modest and reasonable in value.

Transparent, declared, and approved in advance where required.

For legitimate business purposes, such as networking or goodwill.

Gifts or entertainment that could be perceived as influencing a decision must be declined.

8. Record Keeping

Beacon Telematics Ltd will keep accurate and complete financial records and maintain internal controls to evidence the legitimacy of any payments or benefits provided or received.

All hospitality, gifts, or promotional expenses must be recorded in accordance with our internal procedures.

9. Reporting Concerns

Any employee who suspects a breach of this policy should report it via the Company’s Whistleblowing or HR channels. Reports will be treated confidentially, and there will be no retaliation against individuals for reporting genuine concerns in good faith.

10. Training and Communication

All employees will receive regular training on recognising and preventing bribery and corruption. Contractors and third parties will be made aware of this policy as part of our due diligence process.

11. Monitoring and Review

The Company’s Board will regularly review the effectiveness of this policy and take appropriate action to ensure continuous improvement. Internal audits may be carried out to assess compliance.

Approved by:

Managing Director, Beacon Telematics Ltd