1. Policy Statement

PJP Direct LTD T/A LED Beacon Master ("the Company") is committed to conducting its business fairly, honestly, and with integrity. The Company has a zero-tolerance approach to bribery and corruption in all its business dealings and relationships, wherever it operates.

This policy applies to the Company's operations in the United Kingdom and, where relevant, to any overseas activities, and has been adopted in order to comply with the Bribery Act 2010 and to uphold the Company's reputation for ethical conduct.

This policy has been approved by Pat Power, Managing Director, and is fully supported by the Company's senior leadership.

2. Purpose and Scope

The purpose of this policy is to:

•      Set out the Company's responsibilities, and the responsibilities of everyone working for or on behalf of the Company, in observing and upholding a zero-tolerance position on bribery and corruption.

•      Provide information and guidance to those working for the Company on how to recognise and deal with bribery and corruption issues.

•      Ensure compliance with the Bribery Act 2010.

This policy applies to all individuals working at all levels of the Company, including directors, senior managers, officers, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, casual or agency workers, and third parties such as agents, distributors, suppliers, or business partners acting on the Company's behalf (collectively referred to in this policy as "workers").

3. Legal Framework

The Bribery Act 2010 makes it a criminal offence to:

•      Bribe another person, i.e. offer, promise, or give a financial or other advantage to induce or reward the improper performance of a relevant function or activity, or knowing that acceptance of the advantage would itself constitute improper performance (Section 1).

•      Be bribed, i.e. request, agree to receive, or accept a financial or other advantage intending that a relevant function or activity should be performed improperly, or as a reward for such improper performance (Section 2).

•      Bribe a foreign public official in order to obtain or retain business or a business advantage (Section 6).

•      As a commercial organisation, fail to prevent bribery by persons acting on the organisation's behalf (Section 7) — this is a strict liability offence, subject to the defence that the organisation had adequate procedures in place to prevent bribery.

Penalties for individuals can include up to 10 years' imprisonment, an unlimited fine, or both. Organisations can face unlimited fines, exclusion from tendering for public contracts, and serious reputational damage.

4. Definitions

4.1 Bribery

Bribery is offering, promising, giving, requesting, or accepting a financial or other advantage in exchange for improperly performing a relevant function, activity, or duty, or rewarding such improper performance. It can involve cash, gifts, hospitality, preferential treatment, or any other benefit.

4.2 Corruption

Corruption is the abuse of entrusted power or position for private gain. Bribery is one form of corruption; others include fraud, extortion, and abuse of position.

4.3 Facilitation payments

Facilitation payments are small, unofficial payments made to secure or speed up a routine action by a government official or similar person to which the payer is already entitled. These are illegal under the Bribery Act 2010 regardless of local custom or amount, and are strictly prohibited by the Company.

4.4 Kickbacks

A kickback is a payment made in return for a business favour or advantage, typically paid in secret to a person who has influence over a business decision.

4.5 Conflict of interest

A situation in which a worker's personal interests (financial or otherwise) could improperly influence, or appear to influence, their judgement or actions on behalf of the Company.

5. What Is Not Acceptable

It is not acceptable for any worker (or someone acting on their behalf) to:

•      Give, promise to give, or offer a payment, gift, or hospitality with the expectation or hope that a business advantage will be received in return, or to reward a business advantage already given.

•      Give, promise to give, or offer a payment, gift, or hospitality to a government official, agent, or representative to facilitate or speed up a routine or necessary procedure.

•      Accept payment from a third party where the worker knows or suspects that it is offered with the expectation that it will obtain a business advantage for that party.

•      Accept a gift or hospitality from a third party where the worker knows or suspects that it is offered or provided with an expectation that a business advantage will be provided in return.

•      Threaten or retaliate against another worker who has refused to commit a bribery offence, or who has raised concerns about actual or suspected bribery or corruption.

•      Engage in any other activity that might lead to a breach of this policy or the Bribery Act 2010.

6. Gifts, Hospitality, and Entertainment

This policy does not prohibit normal, appropriate hospitality and gifts (given or received) that are proportionate, reasonable, given openly, and intended to build or maintain good business relationships rather than to influence a business decision improperly.

The following principles apply to all gifts and hospitality given or received in connection with Company business:

•      Gifts and hospitality must be modest in value, proportionate, and reasonable in the circumstances.

•      Gifts and hospitality must not be offered to, or accepted from, government officials or their representatives without the prior approval of the Managing Director.

•      Gifts must never be made or accepted in cash or cash equivalents (such as vouchers readily convertible to cash).

•      Gifts and hospitality must not be offered or accepted during, or shortly before or after, any tender process, contract negotiation, or decision that could reasonably be seen to be influenced by them.

•      All gifts and hospitality given or received with an estimated value over £50 must be declared and recorded in the Gifts and Hospitality Register maintained by the Company.

•      If in doubt about whether a gift or hospitality is appropriate, workers must seek guidance from the Managing Director before accepting or offering it.

7. Facilitation Payments and Kickbacks

The Company does not make, and will not accept, facilitation payments or kickbacks of any kind, in the UK or overseas. If a worker is asked to make a payment on the Company's behalf, they should always be alert to the possibility that it may be a facilitation payment or bribe, and should always ask for a receipt detailing the reason for the payment.

If a worker suspects that a facilitation payment or kickback is being requested or offered, they must refuse the request (where safe to do so) and report the matter immediately in accordance with Section 10 of this policy.

Where a worker's personal safety is at risk (for example, when a payment is demanded under duress), the safety of the individual takes priority and the payment may be made; the incident must be reported to the Managing Director as soon as safely possible afterwards.

8. Political Donations, Charitable Donations, and Sponsorship

The Company does not make donations to political parties or political causes. Any charitable donation or sponsorship made on behalf of the Company must be approved in advance by the Managing Director, properly recorded, and must not be used as a means of concealing bribery.

9. Third Parties and Business Relationships

The Company expects the same high standards from all contractors, suppliers, agents, and other business partners acting on its behalf. Appropriate due diligence will be carried out before engaging agents, intermediaries, or other third parties who deal with third parties or public officials on the Company's behalf, and anti-bribery expectations will be reflected in contracts where appropriate.

10. Raising a Concern (Whistleblowing)

Workers are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage. If a worker believes or suspects that a breach of this policy has occurred, or may occur, they must report it as soon as possible in one of the following ways:

•      Speaking directly to their line manager or to Pat Power, Managing Director.

•      Raising the matter in writing, marked confidential, addressed to the Managing Director.

The Company will treat all reports seriously, investigate matters properly, and maintain confidentiality so far as possible. No worker will suffer any form of retaliation, detriment, or victimisation as a result of raising a genuine concern in good faith, even if that concern turns out to be mistaken.

11. Responsibilities

11.1 The Managing Director

Pat Power, as Managing Director, has overall responsibility for this policy and for ensuring it is implemented, monitored, and reviewed effectively, and has ultimate responsibility for compliance with the Bribery Act 2010 across the Company.

11.2 Managers

All managers are responsible for ensuring those reporting to them understand and comply with this policy, and for monitoring compliance within their teams.

11.3 All workers

All workers must read, understand, and comply with this policy, and must avoid any activity that might lead to, or suggest, a breach of this policy. Any worker who is unsure whether a particular act constitutes bribery or corruption should raise it with their manager or the Managing Director before taking any action.

12. Record Keeping

The Company will keep financial records and have appropriate internal controls in place to act as evidence for all payments made and received, and to identify and prevent bribery. All expense claims relating to gifts, hospitality, or expenses incurred with third parties must be submitted in accordance with the Company's expenses procedure and must specifically identify the reason for the expenditure.

13. Training and Communication

This policy will be provided to all new workers as part of their induction. The Company will provide training on this policy, and on the identification and avoidance of bribery, as necessary to ensure workers understand their obligations. Zero tolerance of bribery and corruption will be communicated to all business relationships at the outset, and as appropriate thereafter.

14. Consequences of Breach

Any worker who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. The Company reserves the right to terminate its relationship with any contractor, agent, or other third party working on its behalf if they breach this policy.

The Company may also report suspected criminal conduct to the relevant law enforcement authorities.

15. Monitoring and Review

This policy is reviewed by the Managing Director periodically, and at least annually, to ensure it remains effective and reflects any changes in the law or in the Company's operations. The next scheduled review date is August 2027.

16. Policy Approval

This policy has been approved by:

Signed:

Pat Power

Managing Director

PJP Direct LTD T/A LED Beacon Master

Date: 3rd August 2026