FRTOL01Policy Statement
Xynnar Group Ltd ("the Company") conducts its business honestly, ethically and lawfully. We take a zero-tolerance approach to bribery and corruption in any form, by anyone working for us or on our behalf, anywhere in the world.
We comply with the Bribery Act 2010 and other applicable anti-corruption laws, including the laws of any country where we do business.
02Who This Policy Applies To
This policy applies to the Company's directors, officers, employees, contractors, consultants, agents and anyone else who performs services for or on behalf of the Company ("you").
03What Is Not Allowed
You must not, directly or through anyone else:
- offer, promise or give any payment, gift, hospitality or other advantage to anyone to induce or reward improper conduct, or to obtain or keep business or an advantage;
- request, agree to receive or accept any such advantage;
- offer or give any advantage to a public official, including officials of aviation authorities, examiners or regulators, to influence them in their official role;
- make facilitation payments ("grease payments") to speed up routine actions;
- threaten or retaliate against anyone who refuses to take part in bribery or raises a concern under this policy.
04Gifts and Hospitality
Modest, occasional and proportionate gifts and hospitality given or received in good faith are allowed, provided they are not intended or likely to influence a business decision, are not cash or cash equivalents, are given openly and comply with local law. Any gift or hospitality given or received with a value over £100 must be approved in advance by a director and recorded in the Company's gifts and hospitality register.
05Political and Charitable Donations
The Company does not make political donations. Charitable donations must be approved by a director, be made to a legitimate registered charity, be recorded, and never be used as a disguised bribe.
06Suppliers, Partners and Agents
We choose suppliers, partners and agents carefully, carry out proportionate due diligence, and expect them to meet standards equivalent to this policy. Where appropriate, our contracts include anti-bribery obligations and the right to end the relationship if they are breached.
07Records
We keep accurate books and records of all payments, gifts, hospitality and expenses, with appropriate internal controls. No accounts may be kept "off book".
08Raising Concerns
Anyone who suspects bribery or corruption, or a breach of this policy, should report it as soon as possible to a director of the Company. Concerns raised in good faith will be treated in confidence, and nobody will suffer any detriment for refusing to take part in bribery or for raising a genuine concern.
09Breaches
A breach of this policy may lead to disciplinary action, including dismissal, or the ending of a contract, and may be reported to the authorities. Bribery is a criminal offence that can lead to fines and imprisonment.
10Responsibility and Review
The directors are responsible for this policy, for making sure it is understood, and for reviewing it at least once a year. Approved by the board of Xynnar Group Ltd. Last reviewed 7 November 2026.