Anti-Bribery and Corruption Policy

Applies To: All employees, contractors, agents, and third-party representatives of HSEnergy Group Ltd

If you have any requests concerning your personal information or any queries with regard to these practices please contact us

Policy Statement:

HSEnergy Group Ltd and every subsidiary (“Company”) are committed to the highest standards of honesty, integrity, ethics, transparency and professionalism in dealings with clients, suppliers, competitors and customers alike.

We operate a zero-tolerance approach to bribery and corruption and are fully committed to complying with the Bribery Act 2010, as well as all other applicable laws and regulations relating to anti-bribery and corruption in the United Kingdom.

Bribery and corruption damage trust, harm our reputation, and undermine the solar energy sector’s commitment to sustainability and fairness.

This policy applies to all business activities, particularly those involving the procurement, installation, and maintenance of solar photovoltaic (PV) systems and battery storage solutions.

Purpose:

The purpose of this policy is to:

Prevent bribery and corruption within the company and our responsibilities in observing and upholding the laws against bribery and corruption.
The standards and principles expected of everyone working with or for HSEnergy Group Ltd.
Ensure compliance with applicable UK legislation.
Guide staff and representatives on recognising and avoiding improper conduct.
Safeguard the reputation of HSEnergy Group Ltd and its stakeholders.

Scope:

This policy applies to:

All employees of HSEnergy Group Ltd at every level and grade.
Board members, officers, interns, contractors, agency and temporary staff.
Agents, suppliers, vendors, subcontractors, consultants and any other third parties representing or working with/for HSEnergy Group Ltd

Definitions:

This policy as per the Bribery Act 2010 covers the following bribery offences applicable to our operations:

Bribing another person: For example, offering, promising, or giving a financial or other advantage; intending to induce or reward the improper performance of a relevant function or activity or knowing that accepting the advantage is improper
Being Bribed: For example, requesting, agreeing to receive, or receiving a financial or other advantage; intending a relevant function or activity to be improperly performed or rewarding improper performance or where accepting the advantage is improper
Senior Officer Offence: For example, the corporate body has bribed or has been bribed; the senior officer has consented to or connived in the bribery
Failure to Prevent Bribery: For example, a person associated with a commercial organisation, bribes someone else; intending to obtain or retain a business advantage for the organisation; the organisation did not have in place “adequate procedures”
Corruption: Abuse of entrusted power for private gain.
Facilitation Payments: Small, unofficial payments made to expedite routine government actions – these are strictly prohibited under UK law.
Kickbacks: Undisclosed payments made in return for business favours.

A Bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Employees and others acting for or on behalf of the Company are strictly prohibited from making, soliciting, or receiving any bribes or unauthorised payments.

As part of its anti-bribery measures, the Company accepts transparent, proportionate, reasonable, and bona fide hospitality and promotional expenditure, whether given or received.

This Policy applies to all employees, and they are required to familiarise themselves and comply with this Policy.

Prohibited Practices:

Under this policy, it is strictly prohibited to:

Offer or accept bribes, whether directly or indirectly.
Make or accept facilitation payments (small, unofficial payments to expedite routine actions).
Provide or accept extravagant gifts, hospitality, or entertainment that could improperly influence, or appear to influence, a business decision.
Engage in bribery or corrupt practices.
Ignore or fail to report suspicious behaviour or potential bribery and corruption.

Gifts and Hospitality:

Gifts and hospitality may be accepted only if they are:

Reasonable in value and frequency.
Not intended to influence a business decision.
In line with local laws and business customs.
Pre-approved by management when exceeding a certain value.

Due Diligence and Third Parties:

Before engaging with third parties (e.g. suppliers of solar panels or battery units), we must:

Conduct appropriate background checks.
Include anti-bribery clauses in contracts.
Monitor ongoing relationships for any suspicious behaviour.

Reporting Concerns:

HSEnergy Group Ltd encourages a culture of openness and integrity. All employees and stakeholders are expected to report any concerns related to actual or suspected bribery or corruption. Early reporting is vital to upholding our zero-tolerance policy and ensuring ethical conduct across the organisation.

Reports may be made through the following channels:

The first point of contact for advice is the employee’s immediate manager. The manager will take ownership of the advice and seek further clarification and escalate as per the company management structure as required.
All concerns can and must be ultimately raised confidentially with Michelle Trebilco at trebilco@hsenergy.co.uk. Michelle is designated to handle such matters discreetly and professionally.

Consequences of Non-Compliance:

Violations of this policy may result in:

Disciplinary action, which may include, but is not limited to, termination of employment.
Criminal prosecution, with potential penalties including imprisonment and fines;
Termination of business relationships or contracts with third parties involved.

All employees, officers, and contractors of HSEnergy Group Ltd are expected to uphold the highest standards of integrity and act in accordance with this Anti-Bribery Policy. Specific responsibilities include:

All Staff
- Must not offer, give, solicit, or accept bribes in any form.
- Must report any suspected or actual bribery incidents immediately through the designated reporting channels.
- Are required to complete all mandatory training on anti-bribery and corruption.
- Should seek guidance from the Compliance or Legal team if in doubt about any situation that may involve bribery.
Managers and Supervisors
- Must lead by example and promote a culture of ethical conduct.
- Are responsible for ensuring that their teams understand and comply with the policy.
- Must monitor business activities and report any red flags to Compliance.

Training and Communication:

All employees must complete anti-bribery training annually.

This policy is communicated as follows:

Making available copies of the policy to prospective applicants.
Ensuring all new starters can discuss the policy with line managers / colleagues
Making use of team meetings to discuss the policy and defining areas where practice could be improved
Providing training to all Senior and Line Managers
Including reference to abiding by the policy in staff terms and conditions
Incorporating specific responsibilities into job/role descriptions

Monitoring:

This policy will be monitored to judge to what extent it is working and identify areas of improvement.

Monitoring will relate to every Officer, employee (at any level) and individual acting on the Company’s behalf.

Effective monitoring is an important tool for measuring performance and progress towards adherence to the relevant legal and legislative requirements within this Policy.

HSEnergy Group Ltd has taken steps to reassure staff on issues of confidentially through their communications.

Review:

This policy will be reviewed annually by the Board of Directors to ensure that it remains up to date and reflects the needs and practices of the organisation

The policy may also be reviewed if legislation changes or if monitoring information suggests that policy or practices should be altered.

Acknowledgement

At HSEnergy Group Ltd, we are committed to conducting our business with integrity, transparency, and accountability. Our Anti-Bribery Policy is a key part of this commitment and outlines the standards we expect all employees, partners, and representatives to uphold.

Bribery and corruption pose serious risks—not only to our reputation, but also to the trust our clients, colleagues, and stakeholders place in us. That’s why we take a zero-tolerance approach. Every individual at HSEnergy Group Ltd has a responsibility to understand and apply this policy in their daily work.

Thank you for your continued dedication to maintaining the highest ethical standards and for helping us build a culture we can all be proud of.

Michelle Trebilco
Chief Operating Officer
HSEnergy Group