Anti Bribery Policy and Code of Conduct

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Annaizu Ltd is a UK company that helps employers manage sponsor compliance, immigration support, onboarding, rotas and DBS checks. Employers trust us with their compliance records and with personal information about their people, so we hold ourselves to clear standards of honesty.

This page sets out those standards. It contains our Anti Bribery and Anti Corruption Policy, our Code of Conduct, how we train our team, and who is responsible for compliance.

The policies apply to everyone who works for Annaizu or acts for us. That includes our director, employees, contractors, interns and agency staff, wherever they work. We call all of them "our people" on this page.

If you have a question or a concern about anything here, write to info@annaizu.com.

Anti Bribery and Anti Corruption Policy

1. Our position

We do not pay bribes and we do not take them. It does not matter how small the amount is, who is asking, or how much business depends on it. We would rather lose a contract than win it dishonestly.

We follow the Bribery Act 2010 and the guidance the UK government publishes on it. Our director has approved this policy and is personally responsible for making sure it is followed.

2. What counts as bribery

A bribe is anything of value given to persuade someone to do their job improperly, or to reward them for having done so. It does not have to be money. A gift, a job offer, a discount, a favour or a donation can all be bribes.

Under the Bribery Act 2010 it is a crime to:

  • offer, promise or give a bribe
  • ask for, agree to receive or accept a bribe
  • bribe a foreign public official

A company also commits an offence if it fails to prevent bribery by the people who act for it. Corruption is wider than bribery. It covers any abuse of a position of trust for personal gain.

3. What our people must never do

  • Offer, promise or give anything of value to win business, keep business or gain an unfair advantage.
  • Ask for or accept anything of value in return for a decision, a favour or special treatment.
  • Give anything of value to a public official to influence them. This includes staff of the Home Office, UK Visas and Immigration, the Disclosure and Barring Service, HM Revenue and Customs and local authorities.
  • Make a facilitation payment. That is an unofficial payment to make an official do a routine job, or do it faster. Published government fees and official priority services are fine, as long as there is a receipt.
  • Pay or accept anything for referring or recommending a client.
  • Change, backdate or falsify a compliance record, a right to work check, a DBS result or any report, whether for payment, as a favour or because a customer insists.
  • Use another person, a family member or their own money to do any of these things.
  • Hide a payment, destroy a record or get in the way of an investigation.

4. Where the risks are in our work

Most of our work is in the UK and with UK employers, so our exposure to bribery is limited. The moments where we need to be most careful are these:

  • when we deal with government bodies for a customer, such as on a sponsor licence application or a Home Office audit
  • when a customer under pressure asks us to hide a problem or alter a record
  • when someone offers one of our people money for access to personal data
  • when gifts or hospitality are offered during a sale or a renewal

If any of our people face one of these situations and are unsure what to do, they stop and ask the Compliance Officer.

5. Gifts and hospitality

Normal business courtesy is allowed. A branded pen, a coffee or a working lunch is not a bribe. The test is whether the gift is modest, given openly, and has no strings attached.

These are never allowed:

  • cash, vouchers or gift cards
  • anything given or received while a contract is being negotiated, tendered or renewed
  • anything for a public official beyond tea or coffee at a meeting
  • anything our people would not be happy to tell their manager about

Anything more than a small token must be approved by the Compliance Officer before it is given or accepted. Every approved gift or invitation is written into our gifts and hospitality register, with the date, the value, who gave it and who received it.

If refusing a gift would cause real offence, our people accept it for Annaizu and hand it to the Compliance Officer that week.

6. Donations

We do not give money to political parties, candidates or campaigns. Charitable donations and sponsorships need the director's written approval, go only to registered organisations, and are never linked to a business decision.

7. People who act for us

We do not use referral partners, resellers or commission agents. If we ever appoint someone to act for us, we will first check who they are and who owns them, agree a written contract that bans bribery, and pay them only by bank transfer against an invoice for work they have really done.

8. Conflicts of interest

Our people tell the Compliance Officer about any personal, family or financial interest that could affect their judgment at work, or look as if it might. That includes an interest in a customer, a supplier or a competitor. We record each one and agree how to manage it.

9. Records

We record every payment, expense and gift accurately. We keep no accounts off the books. We keep our register and our training records for at least six years.

10. Keeping this policy working

  • Once a year the Compliance Officer writes down the bribery risks we face and checks that this policy still deals with them.
  • Every six months the Compliance Officer reviews the gifts and hospitality register and a sample of payments.
  • We review this policy every year, and sooner if the law changes or something goes wrong.

11. If someone breaks this policy

Bribery is a crime. Anyone involved can be prosecuted, and so can Annaizu. We treat a breach by an employee as a disciplinary matter that can end in dismissal. We will end our contract with any contractor or supplier who breaks this policy, and we may report the matter to the authorities.

Code of Conduct

1. Why we have a Code

This Code describes how we expect our people to behave at work. It cannot cover every situation, so we ask them to use three questions when they are unsure. Is it legal? Is it honest? Would I be comfortable explaining it to a customer or a regulator? If the answer to any of them is no, they stop and ask.

2. We obey the law

Our people follow the laws and regulations that apply to their work, and they follow our policies. Where a policy asks for more than the law does, they follow the policy.

3. We are honest

We tell the truth to customers, colleagues, suppliers and regulators. We do not commit fraud, help anyone else to commit it, or look away when we see it. That covers false statements, false expense claims, and any misleading description of our services or results.

We never change, backdate or falsify a compliance record, a right to work check, a DBS result, a rota or a report.

4. We do not pay or take bribes

Our Anti Bribery and Anti Corruption Policy is part of this Code. Everyone who works for us must follow it.

5. We follow the rules for immigration advice

Annaizu Ltd is registered with the Immigration Advice Authority (IAA) at Level 1, and our immigration advice is given by our own regulated adviser. Our IAA registration number is F202433304. We follow the IAA Code of Standards. In particular:

  • only a person authorised by the IAA gives immigration advice for us, and only at the level they are authorised for
  • we never mislead a client, the Home Office, the IAA, a court or a tribunal, and we never help a client to do so
  • we act in the best interest of each client and keep their affairs confidential
  • we do not pay or accept anything for referring or recommending a client
  • we do not tout for immigration business or make claims about our success rates
  • we charge fair fees that relate to the work done, and we invoice for them
  • we tell clients in writing about any conflict of interest before we act for them
  • we have a written complaints procedure and we use it

6. We protect personal information

We handle a great deal of personal data, including identity documents, immigration status and criminal record checks. Our people handle it lawfully and only for the purpose it was collected.

They open a record only when their job needs it. Looking someone up out of curiosity, or for anyone outside Annaizu, is forbidden. They keep customer and company information confidential, both while they work for us and after they leave. They report any data breach, or any suspicion of one, to info@annaizu.com straight away.

7. We look after our systems and property

Our people follow our information security rules, protect their passwords, and use company systems, equipment and money only for proper business purposes.

8. We treat people with respect

We treat everyone fairly, with dignity and without prejudice. We do not discriminate against anyone because of age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation.

We do not tolerate bullying, harassment, sexual harassment or victimisation. Our people follow health and safety instructions and report hazards and incidents.

9. We compete fairly

We describe our services accurately and win work on merit. We do not agree prices or share markets with competitors, and we do not swap commercially sensitive information with them. We choose suppliers on merit and treat them fairly.

10. We stand against labour exploitation

We do not tolerate forced labour, child labour or human trafficking in our business or in our supply chain. If our people see signs of labour exploitation at a customer or a supplier, they report it to the Compliance Officer.

11. We keep accurate records

Our business, financial and time records are complete and truthful. We do not help anyone evade tax or launder money, and our people report payments or requests that look suspicious.

12. We are open with regulators

We are truthful and cooperative with government bodies and regulators, whether we are acting for ourselves or for a customer. Any regulatory enquiry, inspection notice or legal request goes to the Compliance Officer on the day it arrives.

13. We speak for Annaizu with care

Only people we have authorised speak for Annaizu in public or to the media. Our people do not post confidential, misleading or offensive material about Annaizu, its customers or their colleagues.

14. What happens if the Code is broken

Breaking this Code can lead to disciplinary action, including dismissal. For contractors and suppliers it can end the contract. We may report serious breaches to the authorities.

15. Our people confirm they have read it

Everyone who works for us confirms in writing that they have read this Code and will follow it. They do this when they join and again every year.

Compliance Training

We train everyone who works for us on the Code of Conduct and the Anti Bribery and Anti Corruption Policy. A policy only works if people know what it says and what to do when something feels wrong.

When we train

WhoWhatWhen
Everyone who joins us, including contractors and internsThe Code of Conduct and the Anti Bribery and Anti Corruption PolicyWithin 30 days of starting
EveryoneA refresher on bothEvery 12 months
ManagersHow to supervise their team, approve gifts and handle a concernWhen they take the role, then every 12 months
People in sales, finance and immigration work, and anyone who deals with government bodiesA session on public officials, gifts and warning signs in paymentsWhen they take the role, then every 12 months

We also run extra training within 30 days of any important change to the law or to these policies, and after any incident that shows a gap.

What the training covers

  • what bribery, corruption and fraud look like, with examples from our own work
  • the offences under the Bribery Act 2010
  • the rules on gifts and hospitality and how to use the register
  • dealing with public officials, and why facilitation payments are banned
  • what to do if a customer asks us to alter a record
  • conflicts of interest
  • how to raise a concern, and the protection the law gives people who do

How we know it has worked

Each course ends with a short test, and the pass mark is 80%. Anyone who does not pass takes the course again. After the course, each person signs to confirm they have read the Code of Conduct.

We keep a training record for each person showing the course, the date and the score, and we keep it for at least six years. Training is compulsory. If someone is more than 30 days late, the Compliance Officer follows it up with them and their manager.

Compliance Officer

The person responsible for compliance at Annaizu Ltd is Satinder Singh, Director and Chief Executive Officer. The contact address is info@annaizu.com.

The Compliance Officer:

  • owns the policies on this page and keeps them up to date
  • assesses our bribery and corruption risks once a year
  • approves gifts and hospitality and keeps the register
  • keeps the register of conflicts of interest
  • arranges the training and keeps the training records
  • receives and investigates concerns, and protects the people who raise them
  • checks the register and a sample of payments every six months
  • answers questions from customers, auditors and regulators about our compliance
  • gives advice to any of our people who are unsure what to do

The Compliance Officer is also our director, so the role carries full authority to act on any finding and full access to the records and people it needs.

Raising a concern

If you think someone at Annaizu has broken these policies or the law, please tell us. This applies to our people, our customers, our suppliers and anyone else who deals with us.

How to tell us

Our people can speak to their manager or to the Compliance Officer. Anyone can write to info@annaizu.com and mark the message for the Compliance Officer. You do not need proof. A genuine suspicion is enough for us to look into it. You can give your name or stay anonymous, though an anonymous report is harder for us to investigate and we may not be able to tell you the outcome.

What we will do

  • We will confirm we have received your report within 7 days.
  • We will tell you how we plan to handle it and keep you updated.
  • We will share your identity only with the people who need it to investigate.
  • We will aim to tell you the outcome within 3 months.
  • We will keep a record of what we did.

How we protect you

Nobody will be dismissed, demoted, harassed or treated unfairly for raising a concern they believe to be true, or for refusing to pay a bribe. That holds even if the concern turns out to be mistaken, and even if Annaizu loses business as a result. Treating someone badly because they spoke up is a disciplinary offence.

Nothing in our contracts or policies stops anyone from making a whistleblowing disclosure.

If you would rather go outside Annaizu

Our Compliance Officer is also our director. If your concern is about the director, or you do not feel able to raise it with us, you can report it to a prescribed person or body. These are the regulators and other bodies named in law. You can also get free and confidential advice from Acas, from the charity Protect, or from your trade union. GOV.UK explains how at Whistleblowing for employees.

About these policies

These policies were approved by Satinder Singh, Director of Annaizu Ltd, on 15 April 2026. We review them every 12 months, and sooner if the law changes.

They follow the guidance the UK government publishes on GOV.UK:

Annaizu Ltd is registered in England and Wales, company number 08425646. Registered office: Figflex Oak House, Reeds Crescent, Watford, WD24 4QP.

See also our Privacy Policy, our Terms and Conditions and our Security page.

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