Anti-Bribery and Corruption Policy

Effective Date: June 2025 Review Date: June 2026

Eton Executive Coaching Ltd

Registered Office: 128 City Road, London, EC1V 2NX UNITED KINGDOM

Company Registration Number: 16385399

Purpose and Principles

Eton Executive Coaching Ltd is committed to operating with integrity, transparency and fairness. We uphold a zero-tolerance approach to bribery and corruption, recognising that ethical conduct is foundational to trust-based coaching relationships and professional credibility.

This policy outlines our responsibilities under the Bribery Act 2010, which applies across both public and private sectors. It also provides guidance for associates, clients and partners on how to identify and respond to bribery-related risks.

Definition of Bribery

Bribery is defined as offering, promising, giving, requesting or accepting an inducement or reward to gain commercial, contractual, regulatory or personal advantage. This includes:

  • Active bribery: offering or giving a bribe

  • Passive bribery: requesting or accepting a bribe

  • Bribery of foreign public officials: seeking business advantage through improper influence

Conviction under the Bribery Act may result in up to 10 years’ imprisonment and unlimited fines.

Prohibited Conduct

All associates and representatives of Eton Executive Coaching Ltd must refrain from:

  • Offering, promising or giving bribes

  • Requesting, agreeing to receive or accepting bribes

  • Making facilitation payments (small unofficial payments to expedite routine actions)

  • Offering or accepting gifts, hospitality or donations that could compromise impartiality or influence decisions

Due Diligence and Ethical Partnerships

We conduct proportionate due diligence on clients, suppliers and collaborators to ensure alignment with anti-bribery principles. We seek to work only with those who demonstrate ethical intent and lawful conduct.

Record-Keeping and Transparency

All financial transactions must be accurately recorded. Misrepresentation, falsification or concealment of records related to bribery or corruption is strictly prohibited.

Reporting and Psychological Safety

We encourage associates and clients to report any concerns or suspected breaches. Reports will be treated confidentially and without retaliation. We aim to create a psychologically safe environment where ethical concerns can be raised and addressed constructively.

Monitoring and Review

We regularly review our practices and policies to ensure compliance and relevance. Breaches will be investigated promptly and may result in disciplinary action, including termination of contracts or legal referral.