Overview
Claim Market Ltd Effective Date: May 2026 Version: 1.0
Purpose
Claim Market Ltd (“the Company”) is committed to conducting all of its business activities with honesty, integrity, and transparency. The purpose of this Anti-Bribery and Anti-Corruption Policy is to prevent, detect, and respond to bribery and corruption risks that may arise in connection with the Company’s operations.
This policy is designed to ensure compliance with all applicable laws and regulations, including the UK Bribery Act 2010, which is widely regarded as one of the strictest anti-bribery regimes globally. The Company recognises that even indirect involvement in bribery or corruption can have serious legal, financial, and reputational consequences. Accordingly, it adopts a proactive and preventative approach to managing these risks.
This policy also establishes clear standards of conduct and provides guidance to all individuals acting on behalf of the Company.
Scope
This policy applies to all employees, directors, officers, contractors, consultants, and any third parties acting on behalf of the Company, regardless of their location or role. It applies to all business activities, including lead generation operations, marketing activities, partner onboarding, supplier relationships, and any interactions with clients or external stakeholders.
The policy also applies to relationships with third-party partners, including solicitors, claims management companies, affiliate marketers, and service providers, recognising that bribery risks may arise through these relationships.
All individuals covered by this policy are expected to comply with its requirements at all times.
Policy Statement
The Company operates a zero-tolerance approach to bribery and corruption. It strictly prohibits any form of bribery, whether direct or indirect, and whether involving public officials, private individuals, or organisations.
No person acting on behalf of the Company may offer, promise, give, request, or accept any financial or other advantage intended to improperly influence a business decision or secure an unfair benefit.
All business decisions must be made solely on legitimate commercial considerations, such as quality, price, and service, and must not be influenced by improper incentives.
Definition of Bribery and Corruption
Bribery involves offering, giving, receiving, or soliciting something of value with the intention of influencing a decision or obtaining an improper advantage. Corruption is a broader concept that includes abuse of power or position for personal or organisational gain.
A “thing of value” can include money, gifts, hospitality, services, discounts, employment opportunities, or any other benefit.
Bribery can occur in both public and private sectors and may involve:
Direct payments or transfers
Indirect arrangements through third parties
Hidden or disguised benefits
Even where no payment is made, the offer or promise of a bribe is sufficient to constitute a breach.
Risk Areas Relevant to the Business
The Company recognises that bribery risks may arise in certain aspects of its operations, particularly in a lead generation environment. These include:
Partner onboarding and referral arrangements
Commission or revenue-sharing agreements
Affiliate marketing relationships
Supplier and vendor selection
Incentives linked to lead volume or quality
There is also a risk that third parties acting on behalf of the Company could engage in improper conduct without the Company’s knowledge. Accordingly, the Company maintains controls to mitigate these risks and expects all partners to operate with integrity.
Prohibited Conduct
The following conduct is strictly prohibited:
Any offer, promise, or provision of a bribe or improper advantage to influence a decision or secure business is not permitted under any circumstances. Similarly, requesting, agreeing to receive, or accepting such an advantage is also prohibited.
The Company does not permit facilitation payments, which are unofficial payments made to expedite routine processes. It also prohibits any form of kickback, undisclosed commission, or arrangement designed to circumvent transparency.
Employees and representatives must not attempt to disguise improper payments as legitimate business expenses, nor may they use third parties to carry out activities that would otherwise be prohibited.
Gifts, Hospitality, and Expenses
The Company recognises that reasonable and proportionate hospitality can be a legitimate part of business relationships. However, such hospitality must always be appropriate, transparent, and not intended to influence a business decision.
Gifts or hospitality may be provided or accepted only where they are modest in value, infrequent, and consistent with normal business practice. They must not create an obligation or expectation of favourable treatment.
Gifts or hospitality must never be offered or accepted:
During active negotiations or onboarding processes
In exchange for business advantage
In cash or cash equivalents
Where they could reasonably be perceived as improper
All such expenditures should be recorded accurately and, where appropriate, approved in advance.
Third-Party Relationships and Due Diligence
The Company acknowledges that third parties present a significant bribery risk. Accordingly, it takes reasonable steps to ensure that all partners, affiliates, and service providers operate in a lawful and ethical manner.
Before entering into a business relationship, the Company may conduct due diligence to assess the integrity and reputation of the third party. This may include reviewing regulatory status, business history, and compliance practices.
Third parties are expected to comply with applicable anti-bribery laws and to act in accordance with principles consistent with this policy. The Company reserves the right to terminate relationships where concerns arise.
Financial Controls and Record Keeping
The Company maintains accurate and complete financial records to ensure transparency and accountability. All transactions must be properly authorised, recorded, and supported by appropriate documentation.
Financial records must reflect the true nature of transactions and must not be used to conceal or misrepresent improper payments. Any discrepancies or irregularities must be investigated promptly.
The Company’s approach to record keeping is aligned with its broader data retention policies, including maintaining records for appropriate periods for audit and legal purposes.
Reporting Concerns
All individuals covered by this policy have a responsibility to report any suspected or actual bribery or corruption. Reports should be made promptly to the Director:
Paul Sibley – Director – admin@claim.market
Reports may relate to:
Suspected bribery
Unusual or suspicious transactions
Concerns about third-party conduct
The Company will treat all reports seriously and confidentially. No individual will be subject to retaliation for raising concerns in good faith, even if those concerns are ultimately not substantiated.
Investigation and Response
Any reported concerns will be investigated appropriately and proportionately. The Company will take steps to establish the facts and determine whether a breach has occurred.
Where misconduct is identified, appropriate action will be taken, which may include disciplinary measures, termination of contracts, and, where necessary, reporting to relevant authorities.
The Company will also review its controls and procedures following any incident to prevent recurrence.
Training and Awareness
The Company recognises the importance of awareness in preventing bribery and corruption. Individuals working for or on behalf of the Company are expected to understand this policy and their responsibilities under it.
Where appropriate, training or guidance may be provided to ensure that individuals are able to identify risks and respond appropriately.
Governance and Responsibility
Responsibility for the implementation and oversight of this policy rests with senior management. A designated individual or function may be appointed to oversee compliance and handle reports of suspected misconduct.
Management is responsible for promoting a culture of integrity and ensuring that appropriate controls are in place across the organisation.
Breaches of Policy
Any breach of this policy will be treated as a serious matter. Individuals who fail to comply may be subject to disciplinary action, up to and including termination of employment or contract.
In addition, breaches may expose individuals and the Company to legal consequences under applicable anti-bribery laws.
Review and Updates
This policy will be reviewed periodically to ensure that it remains effective and reflects current legal requirements and business practices. Updates will be made as necessary.
Contact
For any questions or concerns regarding this policy, please contact:
Email: admin@claim.market
Compliance Contact: Paul Sibley – Director