Ethical business and anti bribery policy

Scope Directors, workers, agents and subcontractors acting for Phone Guys in sales, tenders, purchasing, delivery and business relationships.

Purpose and standard

Phone Guys will compete honestly and make business decisions on legitimate commercial grounds. Bribery, facilitation payments, secret commissions, false records and improper influence are prohibited. No one may offer, request, promise, give or accept an advantage intended to obtain an improper business outcome, including through a third party.

Gifts hospitality and conflicts

Do not give or accept cash, cash equivalents, personal rebates or concealed benefits. Do not offer hospitality or gifts connected with a live tender, award decision, regulatory decision or other situation where impartiality could reasonably be questioned.
Before offering or accepting any other gift or hospitality, disclose its nature, value, parties and business purpose to an uninvolved director and obtain a written decision. The director must record any standing limits or authorisations. Without one, approval is required for each case.
Declare actual or potential conflicts, including personal relationships, outside interests and financial interests in a customer, bidder or supplier. Record how the conflict will be managed and remove the conflicted person from the decision where needed.

Buying and using third parties

The operations lead must check a proposed supplier’s identity, capability and relevant safety, security, labour and environmental risks before committing work. The depth of checks must reflect the risk and value of the relationship. Agree scope, price, access and the ethical standards in writing. Do not use an agent or subcontractor to do something that Phone Guys could not properly do itself.

Director responsibilities

The accountable director will assess bribery risks, approve proportionate controls and communicate them to people exposed to those risks. Commercial pressure must not override a concern. The director will arrange independent consideration when a report concerns a director or usual decision maker.

Tender and payment controls

Provide accurate statements about experience, policies, qualifications, insurance and delivery capability. Obtain evidence before making a claim or answering a declaration.
Record the basis of a purchasing or award decision. Protect confidential bid information and reject requests for hidden benefits or competitor information.
Check invoices against the agreed work and pay an established business through an authorised process. Independently verify unexpected bank-detail changes through a trusted contact route.
Record discounts, commissions, gifts, hospitality, conflicts and exceptions transparently. Do not disguise an improper payment as an expense, donation or consultancy fee.

Labour and supply chain concerns

Watch for indicators of coercion, withheld identity documents, unsafe conditions or recruitment fees imposed on workers. Escalate credible concerns, assess immediate protection needs and obtain appropriate specialist or authority advice. Do not make unsupported claims that a supply chain is free from exploitation. Any separate statutory modern slavery statement requires its own applicability check and approval.

Speaking up and response

Report a suspected breach to the operations lead or directly to an uninvolved director. Record facts and preserve relevant evidence without conducting an unauthorised investigation. The director will assess the report, protect people from retaliation for a good faith concern and arrange an impartial investigation. Reporters may seek lawful external advice or use an appropriate external reporting route. Confidentiality will be limited to what a fair process and legal duties permit.

If personal safety is threatened

Do not put yourself at risk to refuse a demand. Move to safety, contact emergency services where necessary and report the facts to the director as soon as it is safe. Any payment made under an immediate threat must be recorded accurately and reviewed with appropriate advice; it must not be concealed or treated as normal business.

Records and review

Keep decisions and investigation records securely, restrict access and retain them according to their purpose and legal obligations. Review this policy annually and following a significant concern, change in business activity or new high-risk relationship. Existing supplier, anti-bribery and speaking-up pages remain in place.

Questions about this policy

For a policy question or correction, use the Phone Guys contact page. Do not send confidential customer, employee, security or incident information through a public enquiry.