Anti-Bribery and Corruption Policy

AlphaTheta EMEA Limited (“ATE”) is committed to the highest standards of ethics and honesty and we operate a zero-tolerance approach to bribery and corruption.

The giving or receiving of bribes, and any other form of corrupt payment, in any course of conduct involving ATE, is absolutely unacceptable.

We expect all contractors, service providers, suppliers, dealers, distributors and any other third parties who act on our behalf to read and comply with this policy. Failure to do so could result in the termination of business relationships and legal liability.

About this policy

This policy sets out the expected standards of conduct for contractors, service providers, suppliers, dealers, distributors and any other third parties who work for, or on behalf of, ATE anywhere in the world (“Business Partners”).

ATE does not tolerate any form of bribery and corruption and expects its Business Partners to adhere to the same standards. We recognise that market practice varies across the territories in which ATE does business and therefore what is normal and accepted in one place may not be accepted in another. However, we are fully committed to complying with our obligations under all applicable legislation, including the UK’s Bribery Act 2010, the US Foreign Corrupt Practices Act 1977, and any other anti-bribery law, anti-corruption Law, conflict of interest law, and any other applicable law, rule or regulation of similar purpose and effect applicable to either our Business Partners or ATE (“Anti-Bribery and Corruption Laws”), and ensuring that no bribes or corrupt payments are made, offered, sought or obtained by anyone acting on behalf of ATE, anywhere in the world.

Reporting concerns

If you are ever in doubt about a situation you find yourself in and are concerned about a possible breach of this policy or any other bribery or corruption connected with ATE, you must immediately let us know by reporting to your contact at ATE, and the ATE Company Secretary (details below).


You must comply with the Anti-Bribery and Corruption Laws and this policy at all times when acting on behalf of ATE.

We may ask that you provide ATE with the appropriate policies and guidelines applicable to your business and supply chain to prevent the facilitation of bribery and corruption. Your policies and management must demonstrate good governance and effective management.

In particular we ask that your policies relating to this matter are clear and communicated to your staff and your supply chain.

What happens if you don’t comply?

Failure to comply with this policy may result in criminal prosecution under the Anti-Bribery and Corruption Laws. An offence under the Anti-Bribery and Corruption Laws can result in an unlimited fine and/or up to 10 years’ imprisonment. Any breach of this policy may also lead to a termination of your business relationship with ATE.

What you cannot do

Business Partners are prohibited from the following conduct when acting for, or on behalf of, ATE:

  • The giving or receiving of improper financial, or other, advantages whether directly or indirectly during the course of business relationships; and
  • Any other inappropriate conduct which could be perceived to improperly influence an individual’s conduct in their professional or public duty.

Examples of prohibited behaviour include

  • making unofficial payments to officials to obtain any permission, permit or stamp, particularly in connection with importing or exporting goods;
  • appointing any third party or supplier to support or assist you in the provision of services to ATE if you know or have good reason to believe that they have engaged in any corrupt or unlawful conduct including any offences under the Anti-Bribery and Corruption Laws; or
  • paying any third party for the purposes of being a ‘fixer’ to open doors and make connections for ATE overseas.

Facilitation payments

ATE Business Partners must never offer, pay, solicit or accept bribes in any form, including facilitation payments.

Facilitation payments (‘facilitating’, ‘speed’ ‘back-hander’ or ‘grease’ payments) are any payments, usually small cash payments to low-level officials, made as a bribe to secure or expedite the performance of a routine or necessary action or level of service.

Gifts, Hospitality and Entertainment

ATE expects its Business Partners to conduct themselves with integrity, impartiality and honesty at all times when conducting business with, or on behalf of, ATE.

Gifts, hospitality and entertainment can form part of normal business relationships. However, they should only be offered or accepted by ATE Business Partners where lawful and proportionate.

Business Partners are required to keep appropriate records regarding gifts, hospitality and entertainment they provide or receive in connection with their work with, or for, ATE.


If you have any queries, relating to this Policy, please contact the Company Secretary at ATE:

AlphaTheta EMEA Limited
Company Secretary
Unit 39, Tileyard Studios,
Tileyard Road, London, N7 9AH, UK
Telephone +44(0)203 761 7220