Approved by Raymond Cullen, Managing Director — next review January 2027

Anti-Bribery, Corruption & Competition Policy

Cullen Utilities Ltd conducts business ethically, fairly and openly, with a zero-tolerance approach to bribery, corruption and anti-competitive behaviour.

It is the policy of Cullen Utilities Ltd to ensure our business is conducted in accordance with competition law and the Bribery Act 2010, operating in an ethical, professional, fair, honest and open manner. We have a zero-tolerance approach to all forms of bribery and corruption.

What we mean by bribery and corruption

Bribery is the act of promising, giving, receiving or agreeing to receive money or another item of value with the corrupt aim of inducing a person to perform a function or activity improperly. Our zero-tolerance approach covers:

  • The direct or indirect promise, offering or authorisation of anything of value.
  • The offer or receipt of any kickback, loan, fee, reward or other advantage.
  • Aid, donations or voting designed to exert improper influence.
  • Payments for lavish or inappropriate entertainment or travel.
  • Favours, including offers of employment.
  • Facilitation payments, inflated commissions and fake consultancy agreements.

We oppose all forms of bribery, corruption and anti-competitive behaviour, large or small, whether initiated by corrupt officials, companies or individuals, and whether it takes place in the public or private sector, in the UK or abroad.

How we uphold this policy

  • Train all personnel to recognise the signs of bribery and corruption and take steps to avoid it.
  • Encourage employees, subcontractors and business partners to report suspicions through whistleblowing channels or our confidential open-door policy.
  • Understand how bribery could occur in our operations and put control measures in place to prevent it.
  • Apply disciplinary and other sanctions for violations of the policy or the law.
  • Monitor and regularly review this policy, including employee expense records, to ensure its continuing suitability.
  • Provide a copy of this policy statement to all employees.

We implement suitable and sufficient procedures to prevent bribery in line with the six principles: proportionality, top-level commitment, risk assessment, due diligence, communication, and monitoring and review. Failure to comply may result in disciplinary action, including dismissal, as well as civil and criminal charges.

Facilitation and third-party payments

Facilitation payments — typically small payments to low-level officials to secure or speed up a routine action — are prohibited in all circumstances, and any alleged instance must be reported. We do not make contributions or donations to political organisations or candidates. Charitable donations and sponsorship are given according to company policy and never used to gain improper influence. Hospitality, entertainment and any third-party travel or accommodation must be proportionate, never lavish, and never intended to induce or reward inappropriate conduct.

Anti-competitive behaviour

We will not take part in any anti-competitive behaviour, including joint selling or purchasing with competitors, price fixing with retailers or suppliers, or keeping an exclusivity period of over five years. We take all necessary steps to comply with the requirements of the Competition and Markets Authority (CMA) and implement best practice wherever possible.

Controlling fraud

We do everything reasonably practicable to prevent fraud and malpractice. We regularly risk-assess the business and evaluate our fraud-prevention procedures, appoint competent individuals to monitor them, train staff at all levels, and give staff and customers an effective, confidential means of reporting fraud or suspected fraud.

Investigations

We investigate all suspicious behaviour, whether by employees at any level, contractors or third-party suppliers. Investigations are confidential, fair, legal and impartial. Concerns should be reported to your direct manager or, where that is not appropriate, to another member of the management team or the compliance officer. Whistleblowers are protected under law and will not be treated unfairly or dismissed for raising a concern.