Anti-Bribery Policy

Effective date:August 15th, 2026

1. Purpose

Surplus-GY is committed to conducting business with integrity and in full compliance with all applicable laws and regulations. This policy sets out our zero-tolerance approach to bribery and corruption, and what everyone working with us is expected to do.

 

2. Who This Applies To

This policy applies to all employees, vendors, contractors, delivery partners and any third party acting on behalf of Surplus-GY, wherever they are located.

 

3. What Is Prohibited

• Bribery in any form, whether direct or indirect, is strictly prohibited.
• No employee or representative of Surplus-GY may offer, give, solicit or accept any bribe, whether in cash, gifts or any other benefit, to or from any individual, organisation or public official.
• Company funds or resources must not be used to secure an improper advantage.
• You must not use a third party, such as an agent, broker or consultant, to do anything this policy prohibits you from doing yourself.
• You must not offer or accept a kickback, or any payment or benefit given in return for business, a decision or preferential treatment.

This applies whether or not the payment would be considered normal practice locally, and whether or not refusing it means we lose business.

 

4. Facilitation Payments

A facilitation payment is a small unofficial payment made to speed up a routine action someone is already obliged to carry out, such as clearing a shipment, issuing a permit or processing paperwork.

Facilitation payments are prohibited. They are a form of bribery even where they are small, expected or requested directly.

If you are asked for one, refuse, and report it under section 7. You will not be penalised for a delay or a lost opportunity that results from refusing.

Where you believe there is a genuine and immediate risk to someone’s personal safety, keep yourself safe first and report what happened as soon as you are able.

 

5. Gifts and Hospitality

Modest gifts and hospitality can be a normal part of doing business. They become a problem when they are intended to influence a decision, or could reasonably be seen that way.

A gift or hospitality is acceptable only where all of the following are true:

• It is not intended to influence a decision, and is not offered in return for anything
• It is reasonable and proportionate in the circumstances
• It is given openly, not in secret, and never in cash or a cash equivalent
• It would not embarrass Surplus-GY if it were made public
• It complies with local law

Gifts and hospitality to or from public officials require prior approval.

 

6. Donations and Sponsorship

Charitable donations and sponsorships must not be used as a route to improper advantage. Political donations are not made on behalf of Surplus-GY.

 

7. Reporting

Report any suspected bribery, or any request for a bribe or facilitation payment, as soon as possible.

Employees should report to the CEO.

Vendors, delivery partners and third parties should report to admin@surplusgy.com, or use the contact details below.

You may report in confidence. Reports are treated seriously and investigated.

 

8. No Retaliation

Nobody will be penalised for refusing to pay or accept a bribe, or for reporting a concern in good faith, even if the concern turns out to be mistaken. Retaliation against someone who reports or who assists an investigation is itself a breach of this policy.

 

9. Records

All payments, expenses, gifts and hospitality must be recorded accurately and in reasonable detail. No account, invoice or record may be false, incomplete or misleading.

 

10. Consequences

Breaching this policy will result in investigation and may lead to disciplinary action up to and including dismissal, termination of a vendor or partner relationship, removal from the platform, and referral to the authorities.

Bribery is a criminal offence. Individuals who commit it may face prosecution in addition to any action we take.

 

11. Training and Review

We provide training on this policy to employees, and we review it regularly to make sure it continues to reflect how we operate and what the law requires.

 

12. Contact