Anti-Bribery Policy

SECTION 1: Introduction

1.1 “Thrive Architects” (Thrive Architects Limited and Thrive Architects (South
West) Limited operates a zero tolerance policy in respect of any form of
bribery or corruption. The penalties for bribery and corruption are severe.
They include up to 10 years imprisonment for individuals and an unlimited
fine for companies as well as adverse publicity and damage to reputation.

1.2 This Statement of Policy is deliberately succinct. Combating bribery is
fundamentally about common sense and creating a culture of ethical
behaviour, not burdensome procedures.

1.3 The Bribery Act 2010 is not about curtailing legitimate and proportionate
corporate entertainment – which is an important device in establishing and
maintaining good relationships – it is about stopping bribery and corruption.

1.4 Corruption is about the abuse of entrusted power for private gain. This
includes bribery, which is the offering, promising or giving of a bribe (active
bribery) or accepting a bribe (passive bribery). There is also the bribery of
a Foreign Public Official, which is unlikely to apply to Thrive Architects. There
is also the corporate offence where a Company fails to prevent bribery being
carried out on its behalf.

1.5 The Company’s approach to bribery and corruption is underlined not only by
adherence to all relevant legislation but by ensuring, as far as possible, that
its business activities are genuine and ethical. Thrive Architects expects.

SECTION 2: Responsibilities

2.1 The Board of Thrive Architects Limited and Thrive Architects South West
Limited have a duty of care to ensure that the company adheres to this

2.2 All employees have the responsibility to report any misdemeanours to the
HR Director relating to colleagues receiving or giving bribes or being
involved in corruption of any kind relating to this policy. Please refer to the
Whistleblowing Policy v3 for more information.

2.3 The HR Director has a responsibility to review this policy and oversee the
day-to-day practices so its employees to maintain the highest standards of
integrity and conduct in all their business dealings.

SECTION 3: Key Principles

3.1 Integrity – Thrive Architects’ employees must not act in any way that could
undermine or give rise to allegations or doubts about their integrity or
commitment to a zero-tolerance approach to bribery and corruption. In
particular, employees must conduct all business relationships fairly and
honestly and at arms-length.

3.2 Transparency – Thrive Architects’ employees must exercise extreme care
to ensure their business dealings are clear and ethical. This is so important,
particularly in relation to business partnerships (especially those with
agents, intermediaries and the Company’s supply chain); gifts, corporate
hospitality, entertainment and expenses; donations; share dealings; the use
of confidential information and conflicts of interest. Thrive Architects
employees must adhere, at all times, to Company purchasing policies and

3.3 Security and Reporting Bribery – Thrive Architects encourages
employees to immediately report any suspected business wrongdoing to
Allison Osborne (HR Director). All employees are reassured that no
employee will suffer any adverse consequences for refusing to take part in
bribery or corruption, or for reporting suspected business wrongdoing,
including bribery.

3.4 Monitoring and Review – The HR Director will monitor the policy on an
on-going basis and the Board of Thrive Architects Limited will review Policy
compliance annually. As part of this process, if the need arises for changes
to this Policy or wider guidance is required, those changes will be

The company reserves the right to do an internal bribery health check
review as part of our due diligence to ensure that all employees are adhering
to the policy.

3.5 Communication to employees – The policy is given to all new employees
during their induction and is uploaded onto the company internal

All members of staff attend anti-bribery training, be it with an external
training provider or internal CPD sessions. A record of this is kept on file.

3.6 Practical Action – Thrive Architects will enforce its Policy throughout its
employment contracts and updates via the company SharePoint platform.

3.7 Thrive Architects will act firmly in respect of any failure to comply with this
Policy. Any failure to comply by employees may result in summary dismissal
and may also result in criminal prosecution and/or civil proceedings.

SECTION 4: Business Associates Standards

4.1 Thrive Architects will enforce its Policy throughout its agreements with its
supply chain and business partners. Anti-bribery and corruption provisions
will be included in all relevant contracts and agreements with third parties.
This is reflected in our terms and conditions of business that all clients
receive before and during engagement with the company on each project.

4.2 Thrive Architects will look to its business associates and supply chain to
adopt similar policies to Thrive Architects and encourage comparable
arrangements with their own supply chains.

4.3 The company may carry out an audit of supply chain anti bribery policies as
part of its due diligence review.

4.4 Any failure to comply by suppliers will mean that the contractual agreement
may be terminated, and the Company will avoid doing business with that
individual or company in the future.

SECTION 5: Acceptance of Gifts

4.1 Employees must get approval from a senior director if they are allowed to
accept any other type of benefit or gift or item from any supplier or customer
or from anyone else with actual or prospective business relationship with
the Company.

4.2 If any gifts, benefits or item has been approved and received by an
employee, then this must be recorded onto the Anti-Bribery Register.
Details are to be given to the admin team so the register can be kept up to

4.3 Friendships may develop between customers and employees. However, employees should ensure that customers receive a professional service at all times and that any conduct that places a relationship with a client in jeopardy or that may bring the company’s reputation into disrepute is not acceptable.

4.4 Failure to following this policy may lead to a disciplinary, as set out in the Disciplinary Policy v1.

SECTION 6: Communication & Awareness Of This Policy

6.1 This policy is communicated to all Thrive Architects Limited, Thrive Architects (South West) Limited and Thrive Architects (Thames Valley) Limited employees through our induction process and the latest version of the policy is uploaded onto the internal SharePoint, which all employees have access to.

6.2 Thrive Architects Ltd, Thrive Architects (South West) Limited and Thrive Architects (Thames Valley) Limited employees are required to communicate our zero-tolerance approach to modern slavery to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforce our approach as appropriate thereafter.

If you have any concerns about the issues covered in this Policy, you should not hesitate to raise them with Allison Osborne, HR Director at:

Thrive Architects Limited
Building 300, The Grange,
Romsey Road, Michelmersh,
Romsey, Hampshire, SO51 0AE

01794 367703