1. Our Commitment

Hillmorton Design and Development Ltd is committed to conducting all business activities with the highest standards of integrity, honesty, and accountability. This Corporate Ethics Policy applies to all directors, employees, contractors, and any third parties acting on our behalf.

We believe that acting ethically is not just a legal requirement — it is fundamental to building lasting, trusted relationships with our clients, suppliers, and the wider communities we operate in.

2. Anti-Bribery and Corruption

We have a zero-tolerance policy towards bribery and corruption in all its forms. We comply fully with the Bribery Act 2010 and do not offer, give, request, or accept bribes or improper payments of any kind — whether directly or through a third party.

This means we will never:

• Offer or pay bribes to win or retain business.
• Accept bribes or kickbacks in connection with any business decision.
• Make facilitation payments (unofficial payments to expedite routine government actions).
• Use intermediaries to make payments that we would not make directly.

Any breach of this policy will be treated as gross misconduct and may result in termination of employment or the relevant business relationship, as well as referral to the appropriate law enforcement authorities.

3. Gifts and Hospitality

We recognise that reasonable, proportionate gifts and hospitality are a normal part of professional relationships. However, they must never be offered or accepted where they could create an expectation of favourable treatment, or give rise to any appearance of impropriety.

• Gifts or hospitality with a value exceeding £50 must be declared to the Director and recorded.
• Cash gifts must never be accepted or offered.
• No gifts or hospitality should be given or received during active tender or procurement processes.

4. Conflicts of Interest

A conflict of interest arises when personal interests could — or could be seen to — interfere with our professional obligations to our company, clients, or stakeholders.

All directors and staff are required to:

• Declare any actual, potential, or perceived conflicts of interest as soon as they arise.
• Recuse themselves from decisions where a conflict exists or may reasonably appear to exist.
• Not use company resources, information, or relationships for personal gain.

Declarations should be made to the Director in writing and retained on file.

5. Fair Competition

We are committed to competing fairly in the marketplace. We comply with all applicable UK competition law, including the Competition Act 1998. We do not engage in price-fixing, market-sharing, or any other anti-competitive arrangements with competitors or other parties.

6. Confidentiality and Information Integrity

We recognise our obligations to protect confidential information — both our own and that of our clients. All staff and contractors are required to:

• Keep client and business information strictly confidential, both during and after their engagement with us.
• Not misuse or improperly disclose commercially sensitive information.
• Comply with our Information Security Policy and relevant contractual confidentiality obligations.

7. Responsible Procurement

When selecting suppliers and subcontractors, we consider not only commercial terms but also:

• Their commitment to ethical business conduct.
• Their approach to environmental responsibility.
• Their compliance with applicable employment and modern slavery legislation.

We reserve the right to terminate supplier relationships where serious ethical failings are identified.

8. Reporting Concerns (Whistleblowing)

We are committed to creating an environment where concerns can be raised without fear of retaliation. Any person — employee, contractor, or client — who has reasonable grounds to believe that a breach of this policy has occurred or is likely to occur should raise it promptly.

• Concerns should be raised with a Director in the first instance.
• Where the concern involves a Director, it may be escalated in writing to the full Board or, where appropriate, to a relevant regulatory authority.
• We prohibit any form of retaliation against individuals who raise genuine concerns in good faith.