1. Legal basis#
Bribery Act 2010, in particular section 7 (the corporate offence) - we have implemented adequate procedures to prevent bribery.
2. Rules#
- No giving or accepting bribes - ever.
- No facilitation payments - ever, even where common locally.
- Gifts and hospitality must be reasonable, occasional, declared above £50, and never offered in connection with a tender.
- No political donations from corporate funds without board approval.
- Charitable donations only to vetted, registered charities.
- Third-party due diligence on any agent or intermediary.

3. Gifts & hospitality register#
Maintained by the Company Secretary. Reviewed quarterly by the Audit Committee. Anything offered to or accepted from a public official requires pre-approval.
4. Training#
Mandatory annually for all staff. Role-specific training for sales, procurement and any role with public-sector exposure.
5. How to report#
Concerns to ethics@boundless.tel or via the confidential whistleblowing channel.
6. Review & ownership#
Owner: Head of Compliance. Reviewed annually.
Version history
| Version | Date | Change |
|---|---|---|
| v1.0 | 22 April 2026 | Initial publication. |
This document is published by Boundless Telecom Ltd and forms part of our public legal posture. It is a living document - we update it as the regulatory environment, our supply chain or our products change. If anything here is unclear or you'd like a counter-signed copy, contact legal@boundless.tel and we'll respond within one working day.