Anti Bribery & Anti-Corruption & Anti Trust

Anti Bribery & Anti-Corruption & Anti Trust

Anti Bribery Commitment

It is our policy to carry out business fairly, honestly, and openly both at home and abroad. As such we have a zero tolerance approach towards bribery in any part of our operation. Bribery is defined as a promise, offer or gift (financial or otherwise) to bring about the improper performance of a function or activity. Examples of this would be offering a potential client a gift such as a weekend away on the condition they do business with us, or a client offering you a gift on the basis you will reduce the price of our service to them. To meet this commitment the Company has the following systems in place to counter bribery: • Periodical risk assessments will be documented to assess the levels of risk the Company is exposed to in its business. Page 3 Way Moving Group LTD. – Employee Handbook • A whistle-blowing policy is in place, which can be found at the end of the handbook. If you are concerned that bribery has occurred, may occur or is likely to occur we would encourage you to report your concerns. If you suspect or if you are asked to accept or offer a bribe you must report this immediately to the Managing Director. The Company values a proactive anti-bribery stance by any employee. As we take our obligations to prevent bribery being committed very seriously, any breach of our anti bribery policy or procedures will be considered to be gross misconduct and may result in your dismissal. Where you have been involved in or suspected of involvement in bribery that is not connected with this Company, this may still affect your suitability for on-going employment with us.

Objective

Identify and evaluate potential risks of bribery and corruption in the supply chain.

Procedure

1.Maintain a register of all suppliers and subcontractors with details of services provided and geographic locations. (Excel sheet)
2.Evaluate suppliers based on risk factors, including country of operation, type of service, regulatory environment, financial stability, and history of ethical compliance.
3.Ensuring suppliers, we work with are part of the (BAR) British Association of Removals or FIDI members.
4.All suppliers adhere to the of code of conduct of the respective governing bodies that they are affiliated with such as BAR, FIDI.

Communication

•Objective: Ensure that all supply chain partners are aware of and understand our anti-bribery and anti-corruption expectations.
•Procedure:
Conduct awareness sessions or briefings for suppliers on ABAC requirements.
Maintain open channels for suppliers to ask questions or report concerns related to bribery or corruption. To be immediately reported to the company Director.

Monitoring and Continuous Improvement 

•Regularly review supplier performance and compliance through audits, feedback, and performance metrics.
•Investigate any reports of bribery or corruption promptly and take corrective action as necessary.
•Discuss in Managers meetings any concerns about Anti-Bribery.
Anti-Trust – Risk Assessment

Objective

Identify and evaluate potential anti-trust compliance risks in the supply chain.

Procedure

1.Maintain a register of all suppliers and subcontractors, including type of service, geographic location, and market segment. (Excel sheet).
2.Evaluate suppliers based on risk factors such as market share, geographic region, industry practices, and history of regulatory compliance.
3.Assign a risk rating (low, medium, high) to each supplier based on the potential for anti-trust non-compliance.
4.Prioritize monitoring and control measures for suppliers identified as medium or high risk.

Anti Trust and Anti Competition Law

Williams & Yates competes vigorously, fairly and independently for business in every ethical way in every area of every market for Williams & Yates products and services. The antitrust and competition laws of the countries in which Williams & Yates does business are the foundation of competitive free enterprise.

Williams & Yates requires that all employees fully comply with the antitrust and competition laws of the countries in which Williams & Yates does business. It is illegal in the U.S. and many other countries in which Williams & Yates does business to enter into agreements, understandings or discussions with any of our competitors concerning: prices or discounts; terms of conditions of sale, including credit terms; profits, profit margins or costs; shares of the market; distribution practices or channels; bids or the intent to bid; capacity expansion or entering new markets; selection, classification, rejection or termination of customers or classes of customers; sales territories or markets; exchange of competitive information; or any other matter inconsistent with complete freedom of action and independence of the company in the conduct of its business.

In addition, no officer or employee of Williams & Yates may enter into any exclusive dealing arrangement in which the sale or lease of goods or services is conditioned on the customer’s refusal to deal in the goods or services of a competing seller. Also, no officer or employee of Williams & Yates may enter into a tying arrangement in which the sale or lease of the goods or services is conditioned on the sale or lease to the sale or lease of a separate product or service. In addition, no officer or employee of Williams & Yates may enter into any illegal price discrimination between competing customers, nor engage in deceptive trade practices proscribed by US or other law.

Effective Date: August 2025 
Reviewed By: Senior Management 
Next Review Date: August 2026