Anti-Bribery & Corruption Policy

Introduction

Happy Motor Finance Ltd ("we", "us", "our") is committed to conducting business ethically, honestly, and with integrity. We have a zero-tolerance approach to bribery and corruption in all our business activities and relationships.

This Anti-Bribery and Corruption Policy ("Policy") sets out our position on bribery and corruption and provides guidance to all employees, officers, directors, contractors, consultants, and business partners on how to recognise and avoid bribery and corruption. It has been developed in accordance with the Bribery Act 2010 and reflects our commitment to maintaining the highest standards of ethical conduct.

Scope

This Policy applies to:

• All employees of Happy Motor Finance Ltd, regardless of seniority or location
• All directors and officers
• Temporary and agency workers
• Contractors, consultants, and freelancers engaged by us
• Any third party acting on our behalf, including agents, intermediaries, and business partners

All persons covered by this Policy are expected to read, understand, and comply with it. Failure to comply may result in disciplinary action, up to and including dismissal, and may also constitute a criminal offence.

What Is Bribery?

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action that is illegal, unethical, or a breach of trust. Under the Bribery Act 2010, there are four main offences:

• Bribing another person (Section 1): Offering, promising, or giving a financial or other advantage to another person to induce them to perform a relevant function improperly, or to reward them for doing so.
• Being bribed (Section 2): Requesting, agreeing to receive, or accepting a financial or other advantage as a reward for performing a relevant function improperly.
• Bribing a foreign public official (Section 6): Offering, promising, or giving a financial or other advantage to a foreign public official to influence them in their official capacity.
• Failure to prevent bribery (Section 7): A commercial organisation failing to prevent a person associated with it from bribing another person on its behalf.

An advantage can take many forms, including cash, gifts, hospitality, entertainment, travel expenses, donations, favours, preferential treatment, or any other benefit.

Our Policy

We prohibit the following conduct:

• Giving or offering any payment, gift, hospitality, or other benefit to any person with the expectation or hope that a business advantage will be received in return, or to reward a business advantage already given
• Accepting any payment, gift, hospitality, or other benefit from any person that you know or suspect is offered with the expectation that we will provide a business advantage in return
• Making, authorising, or facilitating any payment or transfer of anything of value to a government official, political party, or candidate for political office for the purpose of influencing official action or obtaining an improper advantage
• Threatening or retaliating against another person who has refused to commit a bribery offence or who has raised concerns under this Policy
• Engaging in any other form of corruption, including extortion, fraud, embezzlement, collusion, or abuse of power

Gifts and Hospitality

We recognise that the giving and receiving of reasonable gifts and hospitality is a normal and important part of building business relationships. However, gifts and hospitality can be used as bribes, so we have established the following guidelines:

Acceptable

• Modest gifts of a promotional nature (e.g., branded merchandise) with a value of less than £50
• Reasonable and proportionate business hospitality, such as working lunches or dinners
• Attendance at industry events, conferences, or seminars where there is a genuine business purpose

Not Acceptable

• Cash or cash equivalents (gift cards, vouchers) of any value
• Gifts or hospitality that are lavish, excessive, or disproportionate to the business relationship
• Gifts or hospitality offered during a competitive tender process or negotiation
• Gifts or hospitality to or from public officials or government representatives without prior approval
• Any gift or hospitality that could reasonably be perceived as an attempt to improperly influence a business decision

Recording Requirements

All gifts and hospitality given or received with a value exceeding £25 must be recorded in our Gifts and Hospitality Register. This register is maintained centrally and is subject to periodic review by senior management.

Facilitation Payments

Facilitation payments are unofficial payments made to public officials to speed up or secure the performance of a routine action. Facilitation payments are illegal under the Bribery Act 2010 and are strictly prohibited, regardless of their value or the local customs of any country in which we operate.

Political and Charitable Donations

We do not make donations to political parties, political organisations, or individual politicians. Any charitable donations or sponsorships must be approved by senior management and must not be used as a means of concealing bribery. All charitable donations must be made transparently and recorded accurately in our financial records.

Our Procedures

We have implemented the following procedures to prevent bribery and corruption:

Risk Assessment

We regularly assess the bribery and corruption risks facing our business, taking into account factors such as the nature of our services, the sectors and countries in which we operate, and the types of third parties with whom we do business.

Due Diligence

We conduct proportionate due diligence on business partners, suppliers, and other third parties before entering into business relationships with them. This includes assessing their anti-bribery and corruption policies and procedures.

Financial Controls

We maintain accurate and complete financial records and have appropriate internal controls in place to ensure that all payments and transactions are properly authorised, recorded, and reported. No undisclosed or unrecorded accounts, funds, or assets may be established or maintained.

Contractual Provisions

Where appropriate, we include anti-bribery and corruption provisions in our contracts with third parties, requiring them to comply with the Bribery Act 2010 and our anti-bribery standards.

Training and Communication

We provide anti-bribery and corruption training to all employees, proportionate to the bribery risks they face in their roles. This includes:

• Training for all new employees as part of their induction
• Periodic refresher training for all staff
• Enhanced training for employees in higher-risk roles (e.g., those involved in procurement, sales, or dealing with external parties)
• Regular communication of this Policy and related updates

Reporting Concerns

We encourage all employees, contractors, and business partners to report any suspected or actual instances of bribery or corruption, or any concerns about potential breaches of this Policy. Reports can be made through the following channels:

• Line manager: Raise your concern with your direct line manager in the first instance
• Senior management: If you are not comfortable raising the issue with your line manager, you can raise it with a member of the senior management team
• Whistleblowing: Use our confidential Whistleblowing Policy and procedures to report concerns
• Email: compliance@happymotorfinance.co.uk

We will investigate all reports promptly and thoroughly. We will treat all reports in confidence to the extent possible. No person who raises a genuine concern in good faith will be subjected to any detrimental treatment, including disciplinary action, dismissal, or any other form of retaliation.

Consequences of Breach

Any breach of this Policy is a serious matter and may result in:

• For employees: Disciplinary action, up to and including summary dismissal for gross misconduct
• For contractors and consultants: Immediate termination of the contract
• For business partners: Termination of the business relationship
• Criminal prosecution: Individuals who commit bribery offences may face imprisonment of up to 10 years and/or an unlimited fine under the Bribery Act 2010

Responsibilities

Senior Management

The directors and senior management of Happy Motor Finance Ltd are responsible for:

• Setting the tone from the top by demonstrating commitment to ethical business conduct
• Ensuring this Policy is effectively implemented and communicated
• Providing adequate resources for anti-bribery compliance
• Monitoring and reviewing the effectiveness of this Policy

All Staff

All employees and persons covered by this Policy are responsible for:

• Reading, understanding, and complying with this Policy
• Avoiding any activity that might lead to or suggest a breach of this Policy
• Reporting any suspected breaches or concerns promptly
• Completing required training on anti-bribery and corruption

Review

This Policy is reviewed annually by the directors of Happy Motor Finance Ltd to ensure it remains effective, up to date, and compliant with current legislation. Any significant changes will be communicated to all persons covered by this Policy.

Related Policies

This Policy should be read in conjunction with our other policies, including:

• Anti-Slavery & Human Trafficking Statement
• Complaints Procedure
• Privacy Policy
• Terms & Conditions

Contact Us

If you have any questions about this Policy, please contact us:

• Compliance: compliance@happymotorfinance.co.uk
• General enquiries: info@happymotorfinance.co.uk
• Website: happymotorfinance.co.uk