Last Updated: 07 November 2025
1. Purpose
IM AMBASSADOR LTD is committed to conducting all business with integrity, transparency, and in full compliance with the UK Bribery Act 2010 and other applicable anti-corruption laws.
This Policy sets out our stance on bribery and corruption and provides guidance to ensure that all employees, partners, and representatives act ethically and lawfully at all times.
2. Scope
This Policy applies to:
- All directors, employees, consultants, contractors, and agents of IM AMBASSADOR LTD.
- All subsidiaries, affiliates, and authorised channel partners worldwide.
- All third parties acting on our behalf, including educational institutions, recruitment partners, landlords, and service providers.
Every person working with or for IM AMBASSADOR LTD is expected to uphold this Policy.
3. Statement of Principle
Bribery and corruption are strictly prohibited. We will not:
- Offer, give, solicit, or accept bribes or improper payments;
- Authorise, condone, or ignore corrupt behaviour by others; or
- Engage in conduct that may be perceived as attempting to influence a decision improperly.
Breaches of this Policy may result in disciplinary action, including termination of employment or contract, and may expose individuals to criminal liability.
4. Definitions
Bribery means offering, promising, giving, requesting, or accepting anything of value as an inducement or reward to gain an improper advantage. A “thing of value” includes, but is not limited to:
- Cash or cash equivalents (gift cards, vouchers, debt forgiveness);
- Gifts, hospitality, travel, or entertainment beyond what is reasonable and proportionate;
- Political or charitable donations made to secure a business advantage;
- Favourable job offers or internships;
- Any other benefit that may influence a decision improperly.
Corruption means dishonest or fraudulent conduct by someone in power for personal gain or advantage.
5. Gifts and Hospitality
Reasonable and proportionate business hospitality is acceptable when transparent, lawful, and not intended to influence decision-making. All gifts or hospitality above nominal value must be:
- Approved in advance by senior management; and
- Recorded in the company’s Gifts and Hospitality Register.
Under no circumstances should cash gifts or equivalent benefits be given or received.
6. Third-Party Dealings
IM AMBASSADOR LTD may be held liable for bribes made on its behalf by third parties.
Therefore:
- All agents, representatives, and partners must act in compliance with this Policy;
- Appropriate due diligence should be undertaken before engagement; and
- Written contracts must include anti-bribery clauses where relevant.
Failure by a third party to comply may result in termination of engagement.
7. Dealings with Government Officials
Extra care must be taken in any interaction with public officials, including embassy staff, visa officers, or education regulators. Even small gestures – such as hospitality or donations—can be perceived as bribes. No payment or benefit should be offered to a government official without written approval from senior management.
8. Facilitation Payments
“Facilitation” or “grease” payments (made to expedite routine government actions) are prohibited under the UK Bribery Act and by this Policy. Any request for such a payment must be declined and reported immediately.
9. Political and Charitable Contributions
Political contributions by or on behalf of the company are not permitted.
Charitable donations may only be made for genuine charitable purposes and must never be used to influence business decisions or secure an advantage.
10. Record Keeping
All financial transactions must be:
- Accurately recorded in company accounts;
- Supported by appropriate documentation; and
- Transparent and auditable.
False, misleading, or incomplete records are strictly forbidden.
11. Raising Concerns and Reporting
Anyone who suspects or becomes aware of a potential breach of this Policy must report it promptly via:
- Their line manager; or
- The Compliance Officer at compliance@imambassador.com
Reports will be handled confidentially and in good faith. Retaliation against anyone who raises a concern honestly is strictly prohibited.
12. Responsibilities
- Directors and Management must ensure the Policy is implemented and communicated.
- Employees and Representatives must understand and follow the Policy and attend training where required.
- Channel Partners and Third Parties must acknowledge and adhere to our standards as a condition of continued business.
13. Training and Awareness
IM AMBASSADOR LTD will provide appropriate anti-bribery training to relevant staff and partners. Refresher training may be required periodically.
14. Consequences of Non-Compliance
Any individual found to have engaged in bribery or corruption will face disciplinary action up to and including dismissal or termination of contract. Where appropriate, the matter may be referred to law-enforcement authorities.
15. Monitoring and Review
This Policy is reviewed annually by management and updated as required to reflect changes in legislation or company structure. The latest version will always be available on our website.
16. Contact
For any questions regarding this Policy, contact:
Compliance Department
I’M AMBASSADOR LTD
compliance@imambassador.com