Anti-Bribery, Corruption and Conflicts Policy

The Mining Shop UK Limited prohibits bribery and corruption in every form. This policy applies to directors, employees, contractors, agents, introducers and other persons performing services for or on behalf of the company. It applies to UK and overseas dealings with customers, manufacturers, suppliers, hosting sites, logistics providers, public officials and private organisations.

Darren Waggott, Director, has overall responsibility for proportionate prevention procedures and an ethical culture. Nobody will suffer retaliation for refusing to pay or receive a bribe, even where the refusal results in delay or lost business.

Commercial pressure, local custom and small value do not make an improper payment acceptable.

Nobody acting for the company may offer, promise, give, request or accept a financial or other advantage intended to induce or reward improper performance. Facilitation payments and kickbacks are prohibited. A demand involving personal safety must be reported as soon as it is safe to do so.

Reasonable and proportionate hospitality or gifts may be permitted only where they are lawful, transparent, connected to a legitimate business purpose and not intended to influence a decision. Cash and cash equivalents are not acceptable gifts. Higher-risk or material items require advance approval and must be recorded.

Charitable giving, sponsorship, discounts, commissions, rebates and marketing support must not be used to conceal an improper benefit. Political contributions may not be made on behalf of the company unless lawfully and expressly authorised by the director.

Actual, potential or perceived conflicts must be disclosed before the affected person takes part in a decision. Examples include personal interests in a supplier, family relationships, outside work, secret commissions and opportunities obtained through company information.

Due diligence is proportionate to country, service, ownership, payment route, public-official contact, commission, introducer role and other risk indicators. Written scope, payment terms, competence and anti-bribery expectations are required for higher-risk associated persons. Payments must match genuine documented services and be made through approved, traceable routes.

Prevention procedures follow the principles of proportionate procedures, senior commitment, risk assessment, due diligence, communication and monitoring and review.

Accurate books and records must be maintained. Gifts, hospitality, conflicts, third-party checks, approvals and concerns are recorded where relevant. False descriptions, off-book accounts and undisclosed side arrangements are prohibited.

Concerns should be raised through the Whistleblowing and Speak-Up Policy or to the director. Reports will be handled as confidentially as reasonably possible, assessed impartially and protected from retaliation. Nothing in an NDA prevents protected disclosure or reporting to a competent authority.

A breach may result in access restriction, disciplinary or contractual action, termination and referral to law enforcement or another authority. Controls are reviewed after incidents, material changes and at least annually.