Statement on Bribery and Corruption


Strawberry Star Group takes a zero-tolerance approach to bribery and corruption and we are committed to conducting our global activities free from any form of such behaviour. We also expect the same from any third parties providing services to or on behalf of Strawberry Star Group. The Strawberry Star Group Anti Bribery and Anti-Corruption Policy and Standards (ABC Policy) and the Strawberry Star Group Introducer Policy and Standards (Introducer Policy) extend to all Strawberry Star Group’s business dealings, and they are supported and endorsed by the Board of Directors, which has ultimate responsibility for their implementation. Our ABC Policy and our Introducer Policy are designed to help Strawberry Star Group and its employees comply with the UK Bribery Act 2010 and with applicable local anti-bribery and anti corruption legislation.

Strawberry Star Group ABC Policy and Standards

Strawberry Star Group’s ABC Policy apply to all Strawberry Star Group employees, and are designed to ensure that the Strawberry Star Group employees know how to identify and manage the legal, regulatory and reputational risks associated with bribery and corruption.

Under the ABC Policy, Strawberry Star Group employees are:

  • Prohibited from offering, promising, providing, requesting, accepting or agreeing to receive anything of value (directly or indirectly) to or from any person or entity for:
    • Improperly obtaining or retaining business or securing an advantage; and/or
    • Inducing the recipient to perform his/her role in breach of an expectation of good faith, impartiality or trust.
  • Prohibited from improperly offering, promising or transferring anything of value to a public official (directly or indirectly) to: influence the public official in the exercise of their public functions; obtain or retain business for Strawberry Star Group; or secure an advantage for Strawberry Star Group, its employees or any other entity or person.


Consistent with this, Strawberry Star Group employees are:

  • Prohibited from making facilitation or “grease” payments, even if this represents local practice or custom;
  • Prohibited from providing employment or other work opportunities (e.g., internships or work experience) to ‘connected’ individuals (e.g. individuals with a close family connection to an important client) to improperly obtain or retain business or secure an advantage;
  • Required to carry out appropriate due diligence on third parties before engaging them to perform services for or on our behalf and to include appropriate ABC Policy clauses in contractual arrangements with such third parties;
  • Prohibited from offering/giving/accepting gifts or entertainment to or from third parties unless this is permitted by the Strawberry Star Group Entertainment, Gifts, Hospitality and Promotional Expenditure Policy and the relevant local business policy and/or standard;
  • Prohibited from making any political contributions on the Strawberry Star Group’s behalf. Strawberry Star Group is an apolitical organisation and donations (financial or in kind) to political parties, individuals or campaigns are not permitted. Any exception is a matter for consideration by the Board
  • Required to adhere to our internal requirements regarding: escalation of ABC Policy issues and concerns; timely reporting of suspicions of, or attempted bribery and corruption; and suspected or actual breaches of the ABC Policy;
  • Required to complete mandatory ABC Policy awareness-raising training and any role- specific ABC Policy training as and when assigned.

The ABC Policy contains the minimum controls requirements that Strawberry Star Group employees must follow to comply with the ABC Policy. The ABC Policy provides more detailed requirements regarding, amongst other things, how to deal with facilitation payment requests, gifts & entertainment, charitable donations/community investments, commercial sponsorship, political donations, lobbying, third party relationships and mergers & acquisitions.

Strawberry Star Group Introducer Policy

In addition, due to the bribery and corruption risks associated with third parties who are engaged to generate or retain business or secure a business benefit for Strawberry Star Group, we have a standalone Introducer Policy. Third parties who are defined as “introducers” by Strawberry Star Group include senior advisers, lead generators, and certain other advisers. The Introducer Policy is designed to protect Strawberry Star Group against bribery and corruption risks, system and controls risks, reputational risk and wider legal and regulatory risks associated with these relationships. The Introducer Policy requires employees to risk rate and conduct due diligence on Introducers, obtain approvals for Introducers, and include ABC Policy related contract clauses in written agreements with Introducers. In addition, the Introducer Policy sets out an employee’s responsibilities for the on-going management of introducer relationships, including how to escalate breaches of the Introducer Policy and/or potential introducer related misconduct.

Consequences of Failing to Comply with the ABC and Introducer Policies

Failure to comply with the requirements of our ABC or Introducer Policies may lead to disciplinary action, up to and including dismissal or termination of employment.

This statement was approved by the board of “Strawberry Star Group” and its subsidiaries.