Longcroft Capital — Anti‑Bribery & Corruption Policy (UK)

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Version: 1.0
Effective date: 5 November 2025
Owner: Compliance Lead (currently James Longcroft)
Applies to: All directors, employees, contractors, consultants, volunteers, temporary workers and any third parties acting on Longcroft Capital’s behalf (collectively, “Personnel”).

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1. Purpose and commitment

Longcroft Capital (“the Company”) operates a zero‑tolerance approach to bribery and corruption. We comply with the UK Bribery Act 2010 and expect all Personnel and third parties to do the same. We will implement proportionate, risk‑based procedures and foster a culture of integrity in all our dealings in the UK and internationally.

Top‑level commitment
The Board and senior management (currently the Founder/Director) are committed to preventing bribery and corruption, setting the tone from the top, and providing the resources to maintain effective controls, training, and oversight.

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2. Scope

This policy covers all forms of bribery and corruption, whether public or private, direct or indirect, including through third parties. It applies to all business dealings, transactions, sponsorships, charitable donations, political activity, gifts and hospitality, and facilitation payments.

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3. Definitions (summary)

• Bribe: An inducement or reward offered, promised, given, requested or accepted to gain an improper business advantage.

• Foreign Public Official (FPO): An individual holding a legislative, administrative or judicial position of any kind in a country or territory outside the UK (including at public agencies or state‑owned enterprises).

• Facilitation payment: A small, unofficial payment made to secure or speed up a routine government action.

• Third party/Associated person: Any person or organisation performing services for or on behalf of the Company (e.g., introducers, agents, consultants, JV partners, suppliers).

• Anything of value: Cash, gifts, travel, hospitality, discounts, internships, employment offers, in‑kind benefits, political/charitable contributions, or any other benefit.

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4. Prohibited conduct

You must not (and must ensure no third party on our behalf does):

1. Offer, promise, give, request or accept a bribe of any kind.

2. Offer, promise or give an advantage to a Foreign Public Official to influence them.

3. Make or accept facilitation payments.

4. Falsify records, hide payments, or create “slush funds”.

5. Retaliate against anyone who raises a concern in good faith.

Exception in cases of duress: If a payment is demanded with an immediate threat to life, limb or liberty, you may prioritise personal safety. You must report the incident to the Compliance Lead as soon as practicable and record all details.

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5. Gifts, hospitality, and expenses (G&H)

G&H can be legitimate relationship‑building when reasonable, proportionate and transparent. It is neverpermissible to give or receive G&H to improperly influence a decision or where it could reasonably be perceived as such.

Monetary thresholds and approvals

• Token/low‑value items (≤ £50 per person): Allowed without prior approval if infrequent and proportionate. Record if there is any doubt.

• Standard hospitality/gifts (> £50 and ≤ £100 per person/event): Allowed with prior approval from the Compliance Lead and must be recorded in the G&H Register.

• High‑value items (> £100 per person/event) or cumulative > £300 with the same counterparty in a rolling 12 months: Not permitted without written approval from the Compliance Lead and a documented business rationale.

• Cash, cash‑equivalents, personal discounts, or lavish/indecent hospitality: Prohibited.

Public officials: Any G&H involving public officials requires prior written approval regardless of value.

Transparency: All G&H that require approval must be pre‑cleared and logged in the G&H Register within five working days. When in doubt, declare and seek approval.

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6. Charitable and political activity

• Charitable donations/sponsorships must be for bona fide charitable purposes, transparent, and approved by the Compliance Lead. Due diligence on the recipient is required. No donations may be used to improperly influence a decision.

• Political donations (cash or in‑kind) are prohibited unless expressly approved by the Board and compliant with applicable law. Personnel must not make political contributions on the Company’s behalf without approval.

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7. Third parties and due diligence

We may be liable for bribes paid by third parties acting for us. The engagement of introducers, consultants, intermediaries, JV partners, and key suppliers must follow risk‑based due diligence and contractual controls.

Minimum requirements:

1. Justification: Clear business rationale and scope of services.

2. Screening: Proportionate checks (identity, ownership, reputation, sanctions/PEP screening, negative media).

3. Contractual protections: Written agreement with anti‑bribery warranties, right to audit, termination for breach, and compliance with this policy.

4. Payment controls: Services actually delivered; payments proportionate, transparent, to named bank accounts in the contracting party’s name; no cash; no offshore payments without approval.

5. Monitoring: Periodic review aligned to risk.

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8. Record‑keeping and financial controls

• Maintain accurate, complete, and timely books and records reflecting all transactions and G&H.

• Apply segregation of duties, dual approvals for higher‑risk payments, and documented expense claims with receipts and business purpose.

• Retain records (including G&H and due diligence files) for at least 7 years or longer if required by law/regulation.

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9. Training and communication

• New starters must confirm they have read and understood this policy.

• Annual refresher: proportionate to role and risk.

• This policy will be published internally and provided to relevant third parties.

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10. Reporting concerns (whistleblowing)

We encourage raising concerns early and in good faith. Reports can be made to the Compliance Lead (currently James Longcroft) via james@longcroftcapital.com. Concerns may be raised anonymously. We prohibit retaliation against anyone who reports honestly.

Where appropriate, concerns may also be reported to relevant UK authorities (e.g., Action Fraud, the National Crime Agency) or professional bodies. The Company will cooperate with law enforcement and regulators as required by law.

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11. Responsibilities and enforcement

• All Personnel must comply with this policy and complete required training.

• Managers/Directors must lead by example, ensure controls operate, and address risks in their areas.

• Breaches may result in disciplinary action (up to dismissal), termination of contracts, and reporting to authorities. The Company reserves all rights to seek damages.

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12. Monitoring and review

The Compliance Lead will conduct annual (or more frequent) reviews of this policy and related procedures, reflecting legal changes, enforcement trends, and business growth. Findings will be reported to the Board (or the Director acting as the Board) with actions tracked to completion.

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13. Acknowledgement

All Personnel and relevant third parties must acknowledge receipt of and compliance with this policy.

Signed:
James Longcroft, Founder & Director
Date: 5 November 2025

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Appendix A — Gifts & Hospitality quick rules

• Never offer/accept if it is intended or likely to influence a decision.

• Never offer/accept cash or cash‑equivalents.

• Public officials: pre‑approval required at any value.

• Keep it modest, infrequent, transparent, and business‑related.

• Pre‑clear anything over £50; do not exceed £100 per person per event without written approval; keep cumulative totals with a counterparty ≤ £300 in 12 months unless authorised.

• Record in the G&H Register within five working days when required.

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Appendix B — Third‑party due diligence checklist (summary)

1. Purpose and scope of engagement.

2. Corporate identity and beneficial ownership.

3. Reputation checks; sanctions/PEP screening; adverse media search.

4. Qualifications/track record; references.

5. Proposed remuneration and payment terms; verify reasonableness.

6. Contractual ABAC clauses; audit/termination rights.

7. Ongoing monitoring plan.

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Appendix C — Conflict of interest & declaration form (template)

Name:
Role/Company:
Counterparty (if relevant):
Nature of benefit/relationship:
Estimated value:
Date received/offered:
Business purpose:
Public official involved? Y/N (details)
Approval required? Y/N
I confirm that this disclosure is complete and accurate.
Signature / Date

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Appendix D — Gifts & Hospitality Register (template fields)

• Date

• Giver/Recipient

• Organisation

• Description (gift/hospitality/expense)

• Value (GBP)

• Purpose/Context

• Public official? (Y/N)

• Pre‑a

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