Anti-Bribery and Corruption Policy

1. Purpose and scope

LOVEGATE prohibits bribery and corruption. This policy applies to directors, employees, temporary and contract staff and people acting on our behalf, including relevant agents, consultants and intermediaries, wherever they operate. LOVEGATE must take proportionate steps to prevent bribery under applicable law, including the UK Bribery Act 2010. It covers product sourcing and sales, brand development, advisory assignments, management services and dealings with warehouse and logistics partners.

A bribe is anything of value offered, promised, given, requested or accepted to induce or reward improper conduct. It can involve a private business or a public official and includes indirect payments through another person.

2. Prohibited conduct

Do not offer, seek or accept a bribe, kickback, hidden commission, personal payment to a buyer, or an improper benefit to secure a listing, order or decision. Local custom, low value or the prospect of losing business does not excuse bribery.

Genuine listing fees, promotional support, commissions and discounts must have a legitimate business purpose, be agreed transparently between the businesses, accurately recorded and paid to the proper business recipient. They must not disguise personal benefits.

3. Facilitation payments and personal safety

Unofficial payments to speed up routine actions, such as customs clearance or permits, are prohibited. Use official channels and obtain proper receipts for legitimate fees.

If someone faces an immediate threat to personal safety, prioritise safety and seek emergency assistance where appropriate. Report any demand or payment made under duress as soon as safe, recording the circumstances so management can obtain legal advice and consider required reporting. This is not advance permission for a facilitation payment under ordinary commercial pressure.

4. Gifts and hospitality

Gifts and hospitality must be modest, proportionate, openly provided, for a legitimate business purpose and never intended to influence improperly. Cash and cash equivalents, including vouchers, are prohibited.

During an active tender, listing decision, contract award, price negotiation or similar decision, do not offer or accept gifts or hospitality that could influence, or reasonably appear to influence, the decision. Nominal refreshments incidental to an ordinary business meeting are permitted if appropriate.

Outside those decision periods, gifts or hospitality above £100 per person per occasion require prior written Managing Director approval. Consider repeated or related benefits together to prevent splitting an offer to avoid approval. The threshold is an approval trigger, not a safe harbour.

Record above-threshold gifts and hospitality and relevant repeated, suspicious, attempted or refused offers in the register, including the parties, purpose, value, date and decision. Seek advice if the value or appropriateness is uncertain. No approval or exception can authorise bribery, prohibited cash equivalents or an improper inducement.

5. Product samples

Samples must serve a genuine product evaluation, training or promotional business purpose. Record the business recipient, purpose, product and quantity, with the relevant commercial authorisation. Do not use sample stock as a hidden personal reward or to influence a decision improperly. Unusual quantities, personal recipients or requests around a decision must be referred for approval before supply.

6. Third parties and international trading

Apply proportionate due diligence before engaging a person to act on LOVEGATE's behalf, considering their role, country, ownership, experience and proposed remuneration. Require appropriate anti-bribery commitments in the agreement, monitor concerns and keep fees reasonable for evidenced work.

Pay the correct business recipient through transparent arrangements. Unexplained offshore or third-party accounts, excessive commissions and requests for cash require escalation. Public officials, ports, customs and licensing authorities must be dealt with through lawful official processes. Do not use an intermediary to do what LOVEGATE cannot lawfully do itself.

For advisory and management assignments, disclose conflicts and intermediary remuneration to the appropriate client decision-maker. No advisory fee, success fee or introduction arrangement may conceal a personal benefit or improper payment. A person with a conflict must not approve their own remuneration or exception.

7. Conflicts, donations and records

Declare actual or apparent conflicts, including family or personal connections with a counterparty, before participating in a decision. The conflicted person must not approve their own benefit or exception; refer it to an unconflicted authorised person.

LOVEGATE does not make political contributions. Charitable donations require prior Managing Director approval, a legitimate recipient and accurate records, and must not be used to obtain an improper advantage.

Keep accurate and complete records of payments, discounts, commissions, samples, gifts and hospitality. No false descriptions, undisclosed arrangements or off-book funds are permitted.

8. Reporting and independent escalation

Report suspected bribery, requests for improper payments or concerns promptly to Mark Crump, Managing Director, at mark@lovegatemarketing.com. If the concern involves Mark, report instead to an unconflicted authorised person through info@lovegatemarketing.com, after establishing that the route will not expose the report to someone implicated. Do not send a report or sensitive evidence to a person implicated in the concern.

If an internal route is conflicted or an independent route is needed, approach an independent professional adviser through an independently established contact, or an appropriate external authority. Do not use the general enquiry form to transmit highly sensitive evidence. No person is required to obtain approval from someone implicated before seeking lawful advice or making a protected disclosure.

Information will be handled confidentially as far as practicable, with access limited to those needed to assess and address it. Absolute secrecy cannot be promised where a fair investigation or legal reporting obligation requires disclosure.

9. Protection, investigation and breaches

LOVEGATE prohibits retaliation for refusing a bribe or raising an honestly held concern, even if it proves mistaken. Statutory whistleblowing protection depends on the person's circumstances and the legal requirements; this policy does not restrict protected disclosures.

An unconflicted authorised person must assess concerns, preserve relevant evidence, arrange proportionate investigation and obtain legal advice or make external reports where appropriate. Breaches may lead to disciplinary action up to dismissal, subject to a fair process, or termination of a third-party relationship.

10. Ownership, guidance and review

The Managing Director owns the policy and gifts/hospitality register and must arrange appropriate induction, role-based guidance and refresher training, with records of completion. Monitoring must cover approvals, samples, third parties, reports and recurring risks.

Review the policy at least annually and after a material legal, business or risk change. Keep records of checks and remedial action so that compliance with these requirements can be assessed.