Zero tolerance of bribery, corruption, fraud and the facilitation of tax evasion
1. Our position
Vitalex has a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our dealings, and to complying with the Bribery Act 2010 in the UK and equivalent law wherever we operate.
Bribery is a criminal offence for individuals and for the company. Under section 7 of the Bribery Act, a commercial organisation commits an offence where a person associated with it bribes another to obtain business, unless the organisation can show it had adequate procedures in place. This policy, and the procedures behind it, are part of how we meet that standard.
2. What is prohibited
You must not offer, promise, give, request, agree to receive or accept a bribe, that is, a financial or other advantage intended to induce or reward the improper performance of a function or activity. In particular you must not:
- ▪ give or accept gifts or hospitality that could reasonably be seen as intended to influence a decision;
- ▪ make or accept any payment to secure or reward improper conduct;
- ▪ make a facilitation payment to speed up a routine action by an official; or
- ▪ engage a third party, agent or distributor to do anything that would breach this policy if we did it ourselves.
3. Gifts and hospitality
Reasonable and proportionate business hospitality that is open, genuine and not intended to influence anyone is acceptable. Anything beyond that must be declined or, if received unexpectedly, reported to the Managing Director. If you are in any doubt, ask before you give or accept.
4. Conflicts of interest
You must avoid situations in which your personal interests conflict, or might appear to conflict, with those of Vitalex or its customers. Any actual or potential conflict must be declared to the Managing Director promptly so that it can be managed transparently and recorded.
5. Facilitation of tax evasion
Vitalex will not tolerate the criminal facilitation of tax evasion by any person acting on its behalf, in line with the Criminal Finances Act 2017. You must not engage in, or turn a blind eye to, any arrangement that facilitates tax evasion, and you must report any concern.
6. Fraud
We do not tolerate fraud in any form, whether against Vitalex, against a customer, or committed by anyone acting on our behalf.
The failure to prevent fraud offence introduced by the Economic Crime and Corporate Transparency Act 2023, in force from 1 September 2025, applies to large organisations, those meeting two of the three thresholds of turnover above £36 million, balance sheet total above £18 million, or more than 250 employees. Vitalex does not currently meet those thresholds and the offence does not apply to us. We note it here because we expect to build our procedures toward that standard as the business grows, rather than waiting until we are caught by it.
7. Public procurement integrity
Much of our market is public procurement, where the rules on fair competition are strict and enforcement under the Procurement Act 2023 is real. We will not enter into any arrangement with a competitor that shares markets, fixes prices or coordinates bidding. Where we work with another supplier on a bid, the relationship will be a properly documented subcontracting or consortium arrangement, declared in the bid.
Every statement made in a tender submission must be accurate and capable of substantiation. Overstating a capability, a certification or a partnership in a bid is a matter we treat as seriously as a bribe.
8. Suppliers and partners
We expect the same standards from those who work with us. Clause 18 of our Terms and Conditions of Purchase requires suppliers to comply with anti-bribery law, and clause 22 allows us to suspend or terminate supply where a bribery concern arises. We may end a relationship where a serious concern is not addressed.
9. Raising a concern
If you suspect that a bribe has been offered, requested or paid, or you become aware of any breach of this policy, report it immediately to the Managing Director or, where appropriate, in confidence under our Whistleblowing Policy. Concerns can also be sent to customerservices@vitalexltd.co.uk.
No one will suffer any detriment for refusing to pay or accept a bribe, for refusing to make a facilitation payment, or for raising a genuine concern. That protection applies even where refusing costs us the business.
10. Responsibility and review
The Board owns this policy. Breach may lead to disciplinary action, up to and including dismissal, and to criminal liability for the individuals involved. This policy is reviewed at least annually.