LEGAL

MCD Systems Limited is committed to conducting business ethically, honestly, and with integrity. We have a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate.

This policy applies to all individuals working for or on behalf of MCD Systems Limited, including employees, directors, contractors, consultants, and any third parties acting on our behalf.

The UK Bribery Act 2010 makes it a criminal offence to:

• Offer, promise, or give a bribe (Section 1)
• Request, agree to receive, or accept a bribe (Section 2)
• Bribe a foreign public official (Section 6)
• Fail to prevent bribery by persons associated with an organisation (Section 7)

MCD Systems Limited may be held liable if any person associated with us bribes another person with the intention of obtaining or retaining business, or an advantage in the conduct of business, for our benefit. We therefore take our obligation to prevent bribery seriously and have put in place adequate procedures to prevent it.

Bribery is offering, giving, receiving, or soliciting something of value as an inducement to do something that is dishonest, illegal, or a breach of trust in the course of business. This includes, but is not limited to:

• Cash payments, loans, or financial incentives
• Gifts, hospitality, or entertainment given with the intention of influencing a business decision
• Offering employment or contracts to secure an improper advantage
• Facilitation payments to speed up routine processes
• Political or charitable donations made to gain a commercial advantage

We recognise that the giving and receiving of reasonable and proportionate gifts and hospitality is a normal and accepted part of doing business. However, gifts and hospitality must not be offered, given, solicited, or accepted where they could reasonably be interpreted as an attempt to improperly influence a business decision.

Any gift or hospitality above a nominal value must be disclosed and approved by a director of the company.

All staff and associated persons must:

• Read, understand, and comply with this policy
• Not engage in any form of bribery, whether directly or through third parties
• Report any suspected bribery or corrupt activities immediately
• Not retaliate against anyone who reports a concern in good faith

The directors of MCD Systems Limited are responsible for ensuring this policy is communicated, understood, and adhered to across the organisation.

We maintain accurate financial records and have appropriate internal controls in place to act as evidence that we have adequate procedures to prevent bribery. All accounts, invoices, and other documents and records relating to dealings with third parties are prepared and maintained with strict accuracy and completeness.

If you suspect that bribery or corruption has occurred, or may occur, you should report it immediately. All reports will be treated in confidence and investigated promptly.

We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring that nobody suffers detrimental treatment as a result of refusing to take part in bribery or reporting a concern.

Any breach of this policy will be treated as a serious matter and may result in disciplinary action, up to and including dismissal for employees, or termination of contract for contractors and third parties. Bribery is a criminal offence, and any individual found to have engaged in bribery may also face prosecution and imprisonment.

This policy is reviewed annually and updated as necessary to ensure it remains effective and compliant with current legislation.

Last reviewed: April 2026

If you have any questions about this policy or wish to report a concern, please contact: