1. Introduction

The Pet Academy is committed to conducting its business ethically and in full compliance with all applicable laws and regulations. We recognise that bribery and corruption undermine trust and fairness in business, and we are dedicated to preventing such practices in all our operations. This Anti-Bribery and Corruption Policy outlines our zero-tolerance approach to bribery and corruption and provides clear guidelines for all employees, contractors, and third parties associated with The Pet Academy.

2. Purpose

The purpose of this policy is to:

• Prevent bribery and corruption in any form within The Pet Academy.
• Define and explain what constitutes bribery and corruption.
• Provide clear guidelines on acceptable conduct for all employees, contractors, and third parties.
• Ensure that employees understand how to report concerns or incidents of bribery and corruption.

3. Scope

This policy applies to:

• All employees and contractors of The Pet Academy.
• All third-party suppliers, service providers, consultants, and business partners who engage with The Pet Academy.
• Any individual acting on behalf of The Pet Academy, regardless of location.

4. Definitions

Bribery: Offering, giving, receiving, or soliciting anything of value (e.g., money, gifts, or favours) to influence a business decision or action improperly.

Corruption: The abuse of power or position for personal or financial gain, which includes, but is not limited to, bribery, extortion, and embezzlement.

5. Policy Statement

The Pet Academy has a strict zero-tolerance approach to bribery and corruption. We do not tolerate bribery in any form and are committed to ensuring that no individual, employee, or third party acting on behalf of The Pet Academy engages in such practices. Bribery or corruption, whether direct or indirect, will result in disciplinary action, up to and including termination of employment, and may lead to legal action.

6. Gifts, Hospitality, and Entertainment

The Pet Academy acknowledges that offering or receiving gifts and hospitality may be a normal part of business relationships. However, to avoid the appearance of impropriety, the following guidelines must be followed:

• Gifts and Hospitality: Employees may accept or offer modest gifts or hospitality during business, provided they are not intended to influence any decision or action improperly. Any gift or hospitality must not exceed a value £10 and employees must seek approval from a senior manager before offering or accepting gifts or hospitality of any value.
• Prohibited Gifts: Any gifts or entertainment that are lavish, frequent, or intended to influence a business decision are strictly prohibited.

7. Conflicts of Interest

Employees must avoid situations where their personal interest’s conflict with the interests of The Pet Academy. This includes any financial or personal relationships that could influence or appear to influence business decisions.

• Employees should disclose any potential conflicts of interest to their manager or HR as soon as they become aware of them.
• The Pet Academy reserves the right to take appropriate action in cases where a conflict of interest is identified.

8. Third-Party Relationships

The Pet Academy recognises that we may interact with third parties (e.g., suppliers, agents, contractors, or business partners) who may expose us to risks related to bribery and corruption. We expect all third parties to comply with our Anti-Bribery and Corruption Policy and to operate in a manner consistent with our ethical standards.

• Due Diligence: We will conduct appropriate due diligence on all third parties before engaging in business relationships to assess the risk of bribery and corruption.
• Third-Party Compliance: We will include anti-bribery and corruption clauses in our contracts with third parties, requiring them to comply with our policies.

9. Reporting and Whistleblowing

Employees are encouraged to report any suspected or actual incidents of bribery or corruption. Reports can be made confidentially and anonymously through the following channels:

• Email: [email protected]

The Pet Academy will investigate all reports thoroughly and take appropriate action. Employees who report concerns in good faith will be protected from retaliation, discrimination, or adverse consequences.

10. Training and Awareness

The Pet Academy is committed to ensuring that all employees and relevant third parties are aware of the anti-bribery and corruption requirements. As part of this commitment, we will provide:

• Mandatory Training: All employees will undergo anti-bribery and corruption training upon joining The Pet Academy and receive periodic refresher training.
• Ongoing Awareness: Regular communications will be provided to reinforce the importance of ethical conduct and compliance with this policy.

11. Monitoring and Compliance

The Pet Academy will regularly review and monitor the implementation of this policy to ensure compliance and assess its effectiveness. We will:

• Conduct audits and risk assessments to identify areas where bribery and corruption risks may arise.
• Take corrective action if any violations of this policy are identified.

12. Consequences of Policy Violations

Any employee, contractor, or third party found to be involved in bribery or corruption will face disciplinary action, up to and including termination of employment or contract. Legal action may also be pursued, including reporting violations to law enforcement authorities.

13. Conclusion

The Pet Academy is committed to maintaining a culture of integrity and transparency. We expect all employees, contractors, and third parties to adhere to the highest standards of ethical conduct and to comply with this Anti-Bribery and Corruption Policy.