Anti- Bribery and Corruption 
Policy Statement

Last Updated July 2026

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Nu City Civils Limited values its reputation and is committed to maintaining the highest level of ethical 
standards in the conduct of its business affairs. The actions and conduct of the company’s staff as 
well as others acting on the company’s behalf are key to maintaining these standards.
The purpose of this document is to set out the company’s policy in relation to bribery and corruption. 
The policy applies strictly to all employees, directors, agents, consultants, contractors and to any 
other people or bodies associated with Nu City Civils Limited

Understanding and recognising bribery and corruption
Acts of bribery or corruption are designed to influence an individual in the performance of their duty 
and incline them to act in a way that a reasonable person would consider to be dishonest in the 
circumstances.

Bribery can be defined as offering, promising or giving a financial (or other) advantage to another 
person with the intention of inducing or rewarding that person to act or for having acted in a way 
which a reasonable person would consider improper in the circumstances. Corruption is any form of 
abuse or entrusted power for private gain and may include, but is not limited to, bribery. 

 

Legal obligations
The key UK legislation on which this policy is based is the Bribery Act 2010 and it applies to the 
Company’s conduct both in the UK and abroad. A bribe is an inducement or reward offered, 
promised or provided to gain any commercial, contractual, regulatory or personal advantage.
It is an offence in the UK to:
• Offer, promise or give a financial or other advantage to another person (i.e. bribe a person) 
whether within the UK or abroad, with the intention of inducing or rewarding improper conduct.
• Request, agree to receive or accept a financial or other advantage (i.e. receive a bribe) for or in 
relation to improper conduct. 
• Bribe a foreign public official.
You can be held personally liable for any such offence. 
Nu City Civils Limited will not tolerate bribery or corruption in any form. The firm prohibits the offering, 
giving, solicitation or the acceptance of any bribe or corrupt inducement, whether in cash or in any 
other form:
• to or from any person or company wherever located, whether a public official or public body, or a 
private person or company;
• by any individual employee, director, agent, consultant, contractor or other person or body acting 
on the company’s behalf;
• to gain any commercial, contractual, or regulatory advantage for the company in any way which 
is unethical or to gain any personal advantage, pecuniary or otherwise, for the individual or 
anyone connected with the individual.
This policy is not intended to prohibit the following practices provided they are appropriate, 
proportionate and are properly recorded:
• normal hospitality, if it is not excessive
• fast tracking a process which is available to all on the payment of a fee; and/or

• providing resources to assist a person or body to decide more efficiently, provided it is for this 
purpose only.
It may not always be a simple matter to determine whether a possible course of action is appropriate. 
If you are in any doubt as to whether a possible act might be in breach of this policy or the law, the 
matter should be referred to your line manager. The company will investigate thoroughly any actual or 
suspected breach of this policy, or the spirit of this policy. Employees found to be in breach of this 
policy may be subject to disciplinary action which may ultimately result in their dismissal and police 
prosecution. 

Key risk areas
Bribery can be a risk in many areas of the company. Below are the key areas you should be aware of 
in particular:
Excessive gifts, entertainment and hospitality can be used to exert improper influence on decision 
makers. Gifts entertainment and hospitality are acceptable provided they are of low value.
Facilitation payments are used by businesses or individuals to secure or expedite the performance 
of a routine or necessary action to which the payer has an entitlement as of right. The company will 
not tolerate or excuse such payments being made.

Reciprocal agreements or any other form of ‘quid pro quo’ are never acceptable unless they are 
legitimate business arrangements which are properly documented and approved by management. 
Improper payment to obtain new business, retain existing business or secure any improper advantage 
should never be accepted or made.

Actions by third parties for which the firm may be held responsible can include a range of 
people acting on the company’s behalf. Appropriate due diligence should be undertaken before a third 
party if engaged. Third parties should only be engaged where there is a clear business rationale for 
doing so, with an appropriate contract. Any payments to third parties should be properly authorised 
and recorded.

Record keeping can be exploited to conceal bribes or corrupt practices. We must ensure that we 
have robust controls in place so that our records are accurate and transparent.
Employee responsibility and how to raise a concern
The prevention, detection and reporting of bribery or corruption is the responsibility of all employees 
throughout the company. If you become aware or suspect that an activity or conduct which is 
proposed or has taken place is a bribe or corrupt, then you have a duty to report this. 
Any such incidents should be reported to your line manager or director. 

This policy will be reviewed annually by the Managing Director.
Donal McCulloch
Managing Director