Organisation Elva Talent Ltd
Effective date September 2026
Review At least annually and when material changes occur
1. Policy statement
Elva Talent has zero tolerance for bribery and corruption and is committed to conducting business honestly,
fairly and professionally. We will comply with applicable anti-bribery legislation, including the UK Bribery Act 2010.
2. Prohibited conduct
Offering, promising, giving, requesting or accepting a bribe or improper advantage.
Making facilitation payments or unofficial payments intended to secure or accelerate routine action.
Using a third party to do anything that Elva Talent could not lawfully or ethically do itself.
Providing gifts, hospitality or benefits intended to improperly influence a recruitment, procurement or
commercial decision.
3. Gifts and hospitality
Reasonable, proportionate and transparent business hospitality may be acceptable where it has a genuine
business purpose and is not intended to influence a decision improperly. Cash gifts or cash equivalents must not be offered or accepted.
4. Conflicts of interest
Actual or potential conflicts of interest should be identified and managed transparently. Personal relationships or financial interests must not improperly influence candidate, client, supplier or commercial decisions.
5. Third parties
We expect suppliers, advisers and other third parties acting for or with Elva Talent to conduct business lawfully and ethically. Appropriate due diligence may be undertaken where risk warrants it.
6. Reporting concerns
Suspected bribery, corruption or unethical conduct should be reported promptly to the Director. No person
should suffer retaliation for raising a genuine concern in good faith.
7. Records and review
Business expenses, payments and relevant transactions should be recorded accurately. This policy will be
reviewed periodically and updated where appropriate.