1. Anti-Bribery Policy:

 

Toby Wright LTD prohibits any form of bribery or corrupt practices, whether direct or indirect, involving employees, agents, contractors, business partners, or any third party acting on behalf of the company. This policy covers both domestic and international business activities.

• Guidelines:

  • Employees and representatives must not offer, promise, give, request, or accept bribes, kickbacks, or improper payments to or from any party.

  • All business transactions must be transparently documented and accurately recorded in the company's books and records.

  • Gifts, hospitality, and entertainment provided or received must be reasonable, proportionate, and in compliance with applicable laws and regulations.

 

2. Conflicts of Interest Policy:

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Toby Wright LTD is dedicated to maintaining the highest level of integrity when dealing with customers and partners. All employees are expected to act in the best interests of the company and avoid situations that may compromise their judgment or objectivity.

• Guidelines:

  • Employees must disclose any actual or potential conflicts of interest, including financial interests, personal relationships, or other activities that might affect their professional judgment.

  • A conflict of interest review process will be established to evaluate and address disclosed conflicts appropriately.

 

3. Modern Slavery and Human Trafficking Policy:

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Toby Wright LTD is committed to preventing any involvement in modern slavery or human trafficking, both within the company and through its engagement with third parties.

• Guidelines:

  • The company will not engage in any business relationship with entities involved in modern slavery or human trafficking.

  • Due diligence will be conducted on suppliers, contractors, and business partners to ensure they adhere to ethical labor practices and do not engage in modern slavery.

  • Employees and suppliers will be educated about the signs of modern slavery, and mechanisms will be in place to report any suspicions or concerns.

 

4. Third-Party Engagement Policy:

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Toby Wright LTD recognizes the importance of responsible third-party engagement and will ensure that third parties associated with the company adhere to its ethical standards.

• Guidelines:

  • All third parties engaged by the company will be subject to due diligence to assess their compliance with anti-bribery, conflict of interest, and modern slavery policies.

  • Contracts and agreements with third parties will include clauses obligating them to comply with the company's policies and relevant laws.

  • Regular monitoring and review of third-party relationships will be conducted to ensure ongoing compliance.

 

5. Reporting and Whistleblower Protection:

Toby Wright LTD encourages employees and stakeholders to report any violations or concerns related to bribery, conflicts of interest, or modern slavery.

• Guidelines:

  • A confidential reporting mechanism will be established to facilitate the reporting of potential violations.

  • Non-retaliation protection will be provided to whistleblowers who report in good faith.

 

Summary:

By implementing this comprehensive compliance program, Toby Wright LTD demonstrates its dedication to upholding ethical standards, preventing bribery and conflicts of interest, and ensuring that the company and its third parties are not involved in modern slavery. Through continuous training, monitoring, and enforcement, Toby Wright LTD aims to maintain a culture of integrity and responsible business practices.