Anti-bribery Policy
03 Jan – 31 Dec 2025
1. Purpose
The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company’s business is conducted in a socially responsible manner.
2. Policy statement
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
It is our policy to conduct all of our business in an honest and ethical manner. We take a zero- tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.
Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and a fine. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.
3. Scope
3.1 Who is covered by the policy?
In this policy, third party means any individual or organisation you come into contact with during the course of your work for Dolphin Solutions Ltd, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us.
This policy covers:
- Bribes.
- Gifts and hospitality.
- Facilitation payments.
- Political contributions.
- Charitable contributions.
3.2 Bribes
Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor).
3.3 Gifts and hospitality
Employees must not offer or give any gift or hospitality:
- Which could be regarded as illegal or improper, or which violates the recipient’s policies.
- Unless approved in writing by the managing director, Employees may not accept any gift or hospitality from our business partners.
- If it is in cash.
- If there is any suggestion that a return favour will be expected or implied.
- Unless approved in writing by the Managing Director.
- If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the Managing Director and donated to charity.
3.4 Political Contributions
We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.
3.5 Charitable contributions
Charitable support and donations are acceptable (and indeed are encouraged),whether of in- kind services, knowledge, time, or direct financial contributions.
However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices.
No donation must be offered or made without the prior approval of the Managing Director. All charitable contributions must be publicly disclosed.
4. Your responsibilities
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control.
All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify the Managing Director as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred or may occur in the future.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.
5. Record-keeping
We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.
You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.
6. How to raise a concern
You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with the Managing Director.
7. What to do if you are a victim of bribery or corruption
It is important that you tell the Managing Director as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
8. Protection
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Managing Director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the company’s Grievance Procedure.
9. Training and communication
Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy.
In addition, all employees will be asked to formally accept conformance to this policy on an annual basis.
Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
10. Who is responsible for the policy?
The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Compliance manager has primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation.
Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
11. Monitoring and review
The Compliance manager will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible.
Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.
All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.
Employees are invited to comment on this policy and suggest ways in which it may be improved by the Compliance Manager.
This policy does not form part of any employee’s contract of employment, and it may be amended at any
time.
See also Dolphin’s Conflict of Interest policy.
Modern slavery statement
03 Jan – 31 Dec 2025
This statement applies to Dolphin Solutions Ltd (referred to in this statement as ‘we’ or ‘Dolphin’).
Organisational structure
We are a global leader in the washroom product supply, anything from dispensers to hot air dryers, taps and bins to baby change units, every item we sell is intelligently designed, not just to look good but be truly fit-for-purpose.
The business is led by a Senior Strategy Team.
The labour supplied to Dolphin in pursuance of its operation is carried out in the main premises located in Bodiam, East Sussex and our showroom in London.
Definitions
Dolphin considers that modern slavery encompasses:
- Human trafficking.
- Forced work, through mental or physical threat.
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
- Being dehumanised, treated as a commodity or being bought or sold as property.
- Being physically constrained or to have restriction placed on freedom of movement.
Commitment
Dolphin acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.
We understand that this requires an ongoing review of both our internal practices in relation to our labour force and, additionally, our supply chains.
Dolphin does not do business with any organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to Dolphin in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking.
We strictly adhere to the minimum standards required in relation to our responsibilities under relevant employment legislation in the United Kingdom, and in many cases exceed those minimums in relation to our employees.
Supply chains
In order to fulfil its activities, Dolphin’s main supply chains are those related to the supply of washroom goods from various suppliers in the United Kingdom, Europe, China and Taiwan.
We understand that our first-tier suppliers may be intermediary traders and therefore have further contractual relationships with lower-tier suppliers.
Potential exposure
Dolphin considers its main exposure to the risk of slavery and human trafficking to exist in its supply chains because they involve the provision of labour in countries where protection against breaches of human rights may be limited.
In general, we consider our exposure to slavery/human trafficking to be relatively limited.
Steps
Dolphin carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
We have not, to our knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, Dolphin is reviewing its supply chain management process to include:
- Termination powers if the supplier is, or is suspected, to be involved in modern slavery.
- Identification and assessment of potential risks in our supply chains.
- Impact assessments of our services upon potential instances of slavery.
- Action plans to address risk to modern slavery.
- Zero-tolerance policy towards modern slavery.
- Training needed for our team on modern slavery.
Policies
Dolphin has the following policies which further define our stance on modern slavery:
- Corporate Social Responsibility Policy.
- Supplier Code of Conduct.
- Equal Opportunities and Diversity Policy.