Updated: January 2026
Grays of Cambridge (International) Ltd is committed to promoting and maintaining the highest possible ethical standards in relation to all of its business activities. It wants to ensure that all staff and associated persons are: a) aware that Grays has a zero tolerance policy towards bribery & corruption, b) understand the Policy and c) will adhere to the relevant provisions.
The Principles behind the Policy:
• Compliance with anti-bribery laws, rules and regulations, not just within the UK, but also in any other country within which the Company may carry out its business.
• Staff and persons associated with the Company are aware of the risks and are encouraged to be vigilant to recognise, prevent and avoid any breach of this policy.
• Staff and persons associated with the Company report any wrongdoing (whether by themselves or others).
• The Company has appropriate reporting channels to ensure information can be effectively dealt with.
• The Company maintains a rigorous and effective framework for dealing with any suspected instances of bribery or other unethical conduct which will be reviewed annually.
The policy applies to all permanent and temporary employees of the Company (including its intermediaries, subsidiaries and associated companies). It also applies to any individual or corporate entity associated with the Company or who performs functions in relation to, or for and on behalf of, the Company, including, but not limited to, directors, agency workers, casual workers, contractors, consultants, seconded staff, agents, suppliers and sponsors (“associated persons”).
The Bribery Act 2010 regulates the Company’s conduct both in the UK and abroad, it is an offence to:
• Offer, promise or give a bribe as an inducement or reward to gain any commercial, contractual, regulatory or personal advantage.
• Request, agree to receive or accept a bribe.
• Bribe a foreign public official.
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
The Company is potentially liable for an offence and under the Act, individuals can be held personally liable too.
The Company can suffer unlimited fines and the risk of substantial reputational damage.
If any person is in doubt as to what might amount to bribery (or other unethical conduct) or might constitute a breach of this policy, they should refer the matter to their Director or to Paul Gray, the Company’s Anti-Corruption Officer (ACO) who can give advice or arrange training as appropriate.
If any member of staff is offered or receive any business gifts/corporate hospitality/tickets from third parties such as clients, customers, contractors and suppliers you must get written confirmation from your line manager that you can accept it.
The giving of business gifts to clients, customers, contractors and suppliers is not prohibited provided it is approved in advance by a Director of the Company.
The Company has issued specific guidance on the issue of match tickets, please ask your manager if you need a copy of this.
Future contracts or agreements entered into by or on behalf of the Company should contain a clause stating that the Grays has a zero tolerance to bribery and that the consequences of a bribery offence should include Grays right to terminate the contract.
The Company recognises that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this policy is expected of all employees and associated persons at all times.
For the avoidance of doubt, any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government procedure or process, otherwise known as a “facilitation payment”, is also strictly prohibited.
In the event of a reported instance or suspected instance of bribery, confidentiality will be maintained during the investigation as much as is practical and appropriate in the circumstances. The Company is committed to taking appropriate action and this could include reporting the matter to an appropriate external body.
The Company will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
Breach of any of the provisions of this policy by an employee will constitute a disciplinary offence and will be dealt with in accordance with the Company’s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render the employee liable to summary dismissal.
As far as associated persons are concerned, breach of this policy could lead to the suspension or termination of any relevant contract, sub-contract or other agreement with the associated person.
The following is a non-exhaustive list of possible issues which may raise bribery concerns and which you should report in accordance with the reporting procedure set out above:
• You are offered a gift or hospitality by a third party.
• You receive an invoice from a third party that appears to be non-standard or extraordinary.
• A third party insists on receiving a commission or fee before committing to signing a contract with the Company, or carrying out a government function or process for the Company.
• A third party requests payment in cash, or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made.
• A third party requests an unexpected additional commission or fee to facilitate a service.
• A third party demands lavish, extraordinary or excessive gifts or hospitality before commencing or continuing contractual negotiations or provision of services.
