Last updated: 20 September 2026
This policy sets out how DEVIGO DIGITAL LIMITED ("Devigo", "we", "us") approaches bribery and corruption, and what we expect of everyone who works for us or with us. It reflects our obligations under the Bribery Act 2010.
We have a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings, wherever we operate.
Who we are
- Company: DEVIGO DIGITAL LIMITED
- Company number: 16571975
- Registered address: C/O The Accountancy Partnership, Suite 5, 5th Floor, City Reach, 5 Greenwich View Place, London, E14 9NN
- Contact for this policy: webmaster@devigo.co.uk
Who this policy applies to
This policy applies to everyone acting for Devigo or on our behalf. That includes directors, employees, contractors, freelancers, consultants, agents and any third party who performs services for us or represents us. Where we refer to "you" below, we mean anyone in that group.
It applies to all our activities, in the UK and overseas.
What the law says
The Bribery Act 2010 creates four offences:
- Offering, promising or giving a bribe (active bribery)
- Requesting, agreeing to receive or accepting a bribe (passive bribery)
- Bribing a foreign public official to obtain or retain business
- Failure by a commercial organisation to prevent bribery carried out by someone associated with it
The fourth offence is a corporate one. A company is liable where a person associated with it bribes someone to win or keep business for that company, unless the company can show it had adequate procedures in place to prevent it. This policy, and the procedures described in it, form part of our adequate procedures.
Penalties are serious. Individuals can face up to 10 years' imprisonment and an unlimited fine. Organisations can face an unlimited fine, confiscation of profits and exclusion from public contracts.
What we mean by a bribe
A bribe is a financial or other advantage offered, promised, given, requested or accepted to induce or reward someone for performing a function or activity improperly, or where accepting it would itself be improper.
It does not have to be money. It can be a gift, hospitality, a discount, a favour, a job for a relative, a donation, a loan, use of a property or anything else of value. It does not have to be paid directly; using an intermediary makes no difference. It does not matter whether the advantage is ever actually received, or whether the business was won.
What you must not do
You must not:
- Offer, promise, give, request, agree to receive or accept a bribe in any form
- Offer or accept a gift or hospitality intended to influence a business decision, or that could reasonably be seen that way
- Make a facilitation payment; see below
- Use a third party, agent, introducer or supplier to do anything this policy prohibits
- Retaliate against, or threaten, anyone who has refused to pay or accept a bribe, or who has raised a concern under this policy
- Do anything that would cause Devigo to breach the Bribery Act 2010 or equivalent anti-corruption law in another country
If you are asked to do any of these things, refuse and report it (see "Raising a concern").
Gifts and hospitality
This policy does not prohibit normal and appropriate hospitality, or modest gifts given or received as a matter of ordinary business courtesy.
A gift or item of hospitality is acceptable only where all of the following are true:
- It is not made with the intention of influencing a decision, obtaining favourable treatment or rewarding a favour
- It complies with local law
- It is given openly and in Devigo's name, not secretly and not to an individual's personal account
- It is of an appropriate and proportionate value given the circumstances
- It is reasonable and justifiable, and you would be comfortable with it being made public
- It is not cash or a cash equivalent such as a gift card or voucher
As a guide, gifts or hospitality with a value above £100 per person should be approved in advance by a director. Anything offered by or to a public official should be approved in advance regardless of value.
If you are unsure whether something is acceptable, ask before you accept or offer it. The test we apply is simple: would this look reasonable to a client, a regulator or a journalist who saw it in full?
Facilitation payments and kickbacks
Facilitation payments are small unofficial payments made to secure or speed up a routine action by an official. Kickbacks are payments made in return for a business favour or advantage.
We do not make or accept either, in any form, anywhere. Facilitation payments are illegal under the Bribery Act 2010 even where they are customary locally.
If you are put under pressure to make such a payment, or you make one because you genuinely believe your safety or liberty is at risk, report it to a director at the earliest safe opportunity so it can be recorded and handled properly.
Charitable and political donations
We do not make political donations.
We may support charities and community causes, including the meetups and networking groups we are involved with. Any charitable donation must be to a legitimate registered organisation, must be made transparently and must not be used as a route to obtain or reward business advantage. Donations requested by a client or prospective client during a live sales process should be declined or deferred.
Suppliers, subcontractors and partners
We work with freelancers, subcontractors, referral partners and other agencies. We expect them to meet the standards in this policy when acting for us.
In practice that means:
- We carry out proportionate checks on new suppliers and partners before engaging them
- Contracts with subcontractors and partners include the expectation that they comply with the Bribery Act 2010
- Referral or introducer arrangements are documented, with the commission or fee set out in writing and disclosed to the client where relevant
- We do not pay commissions or fees that are disproportionate to the service actually provided, or that are routed through unexplained intermediaries
Where we have a cross-referral arrangement with another business, both sides should be open about it with the client. Transparency about how a referral works removes most of the risk here.
Record keeping
We keep accurate books and records. All expenses, commissions, referral fees, gifts and hospitality must be recorded honestly and in reasonable detail, with receipts kept where available. No account, invoice or record may be false, misleading or incomplete, and no off-book arrangements are permitted.
We maintain a register of gifts and hospitality given or received above the threshold set out above, and of any approvals granted.
Your responsibilities
You must read, understand and comply with this policy. Preventing and reporting bribery is the responsibility of everyone working for or with Devigo.
You must avoid any activity that might lead to a breach of this policy, and you must tell us as soon as possible if you believe a breach has occurred or may occur in future.
Raising a concern
If you are offered a bribe, are asked to make one, suspect that one has taken place or may take place, or are unsure whether something is acceptable, raise it. You can do so by emailing webmaster@devigo.co.uk or by speaking to a director directly.
We would rather hear a concern that turns out to be nothing than not hear one at all. Concerns raised in good faith will be taken seriously, investigated and kept confidential so far as we are able.
We will not tolerate retaliation of any kind against someone who raises a concern in good faith or who refuses to take part in bribery, even where that refusal costs us business. If you believe you have suffered any detriment for doing so, tell a director immediately.
You may also report concerns about criminal conduct directly to the police or to Action Fraud.
Breaches of this policy
A breach of this policy is a serious matter. For employees it may result in disciplinary action up to and including dismissal for gross misconduct. For contractors, suppliers and partners it may result in termination of the engagement or contract. Where the conduct may be criminal, we will report it to the appropriate authorities.
Monitoring and review
The directors are responsible for this policy and for ensuring it is applied and remains effective. We review it at least annually and whenever there is a material change to our business, our risk profile or the law.
Contact
Questions about this policy, or to report a concern: webmaster@devigo.co.uk