Business Integrity & Compliance Policy

1. Purpose

Bull Trading Limited is committed to conducting business ethically, responsibly, and in compliance with all applicable laws. This policy sets out our expectations and requirements relating to conduct, anti-bribery, anti-corruption, money laundering, right-to-work, fair pay, whistleblowing, and the protection of confidential and personal information.

2. Scope

This policy applies to:

• All employees of Bull Trading Limited
• Directors, agency staff, contractors, and temporary workers
• All suppliers, subcontractors, and business partners acting on our behalf

3. Code of Conduct

All employees must:

• Act with honesty, integrity, and professionalism at all times
• Treat colleagues, customers, and suppliers with respect and fairness
• Avoid behaviour that could damage Bull Trading Limited’s reputation
• Declare any conflicts of interest immediately
• Comply with all company policies and legal requirements

Breaches of the Code of Conduct may result in disciplinary action.

4. Anti-Bribery and Anti-Corruption

Bull Trading Limited has zero tolerance for bribery and corruption.

Employees must not:

• Offer, give, request, or accept bribes or improper payments
• Provide gifts, favours, or hospitality intended to influence decisions
• Engage in facilitation payments of any kind
• Use third parties to carry out corrupt activities

All hospitality or gifts must be reasonable, proportionate, and recorded where required.

Any suspicion of bribery must be reported immediately.

5. Anti-Money Laundering (AML)

We are committed to preventing our business from being used for money laundering or financial crime.

Employees must:

• Conduct appropriate due diligence when dealing with suppliers and customers
• Report any suspicious financial activity (e.g., unusual payments, reluctance to provide information, cash transactions outside normal practice)
• Ensure accurate financial records are kept and reviewed

Knowingly engaging in money laundering is a criminal offence and will result in immediate disciplinary action.

6. Employee Right to Work

Bull Trading Limited complies fully with UK employment law and right-to-work legislation.

We ensure that:

• All employees have verified and valid right-to-work documentation
• Records are maintained and reviewed in line with legal requirements
• No worker is employed illegally or through exploitative arrangements

We do not tolerate the use of forced, coerced, or trafficked labour.

7. Fair Pay, Living Wage & PAYE Compliance

Bull Trading Limited is committed to fair and lawful pay practices.

We ensure that:

• All employees are paid at or above the UK National Minimum Wage or Real Living Wage where applicable
• PAYE (Pay As You Earn) deductions, tax, National Insurance, and statutory payments are made correctly and in compliance with HMRC requirements
• Employees receive accurate payslips and information about their pay
• Overtime, holidays, and statutory pay are administered legally and fairly

Unlawful deductions or unfair pay practices are strictly prohibited.

8. Whistleblowing

Bull Trading Limited encourages all employees to report wrongdoing without fear of retaliation.

Whistleblowing may include:

• Fraud
• Health and safety risks
• Illegal activity
• Bribery or corruption
• Misuse of company funds
• Breaches of confidentiality
• Any behaviour that violates this policy

We provide:

• Confidential reporting channels
• Protection from victimisation or dismissal
• Prompt, fair investigations into all legitimate concerns

Whistleblowers will be supported throughout the process.

9. Protecting Confidential & Personal Information

Bull Trading Limited is committed to safeguarding commercially sensitive, personal, and confidential data.

Employees must:

• Handle all personal data in line with UK GDPR and data protection laws
• Only access information required for their job role
• Keep customer, supplier, and employee information secure
• Use secure methods for storing and transmitting data
• Not share confidential or personal information with unauthorised parties
• Report data breaches immediately

Misuse of company information may lead to disciplinary action or legal consequences.

10. Responsibilities

• Directors and management are responsible for promoting compliance and ensuring systems are in place to uphold this policy.
• Employees must follow the policy and report concerns promptly.
• Suppliers and partners must maintain equivalent standards and support compliance efforts.

11. Monitoring & Review

This policy will be:

• Reviewed annually or when legislation changes
• Communicated to all employees
• Used to guide training, compliance checks, and due diligence

Bull Trading Limited is committed to continually improving ethical, transparent, and responsible business practices.