1. Policy statement

The Scottish Shutter Company (trading name of Rocknowe Interiors Limited) is committed to conducting business ethically and with integrity. We have a zero tolerance approach to bribery and corruption in all forms.

This policy sets out our commitment to compliance with the Bribery Act 2010 and the Criminal Finances Act 2017, and our expectations of all individuals associated with our business.

2. Scope

This policy applies to all employees, directors, contractors, and business partners of The Scottish Shutter Company. It covers all business dealings and transactions in every country in which we operate.

3. What constitutes bribery

Bribery is the offering, giving, receiving, or soliciting of any item of value to influence the actions of an official or other person in a position of trust. This includes:

Bribes, whether in cash or any other form of inducement.
Kickbacks or secret commissions.
Facilitation payments, regardless of local custom or practice.
Offering anything of value to improperly influence a business decision.

4. Tax evasion facilitation

Under the Criminal Finances Act 2017, it is an offence for a business to fail to prevent the facilitation of tax evasion by anyone acting on its behalf. All employees, contractors, and business partners must ensure they do not facilitate, or turn a blind eye to, tax evasion by any party.

This includes accepting or making payments in cash to avoid VAT, falsifying invoices, or knowingly participating in arrangements designed to evade tax.

5. Gifts and hospitality

We recognise that reasonable and proportionate hospitality is a normal and important part of doing business. Gifts and hospitality may be accepted or offered provided they are:

Reasonable and proportionate in value.
Not intended to influence a business decision or secure an unfair advantage.
Given or received openly and transparently.
Not in the form of cash or cash equivalents.

6. Practical examples

The following examples illustrate how this policy applies in practice:

Supplier hospitality: A supplier invites you to a trade show dinner or offers tickets to an event. This is acceptable provided it is reasonable, openly declared, and not tied to placing an order or favouring that supplier over others.
Referral fees: A subcontractor or trade contact offers a payment for recommending their services to customers. This must be declined unless it has been formally agreed, disclosed, and approved by a director.
Exclusive pricing arrangements: A supplier offers a significant discount on the condition that we do not use competing suppliers. This must be discussed with a director before any commitment is made, as it could create a conflict of interest.

7. Record keeping

All gifts and hospitality given or received must be recorded. Employees should notify David Browne of any gift or hospitality that exceeds a nominal value, so that it can be recorded and reviewed.

8. Reporting concerns

All employees and business partners are encouraged to report any concerns about bribery, corruption, or the facilitation of tax evasion. Reports should be made to David Browne in confidence.

If the concern involves David Browne, or if you would prefer to speak to someone else, reports can be made to David D'Ambrosio (Technical Director) in confidence.

We are committed to ensuring that anyone who raises a genuine concern in good faith will not suffer any detrimental treatment as a result.

9. Investigation and outcomes

All concerns raised under this policy will be taken seriously and investigated promptly. The investigation will be conducted by a director not involved in the matter. The person who raised the concern will be informed of the outcome, and a record of the investigation will be kept.

10. Consequences of breach

Any breach of this policy will be treated as a serious matter and may result in disciplinary action, up to and including dismissal. A breach may also constitute a criminal offence, which could result in prosecution and imprisonment for the individual concerned.

11. Training and awareness

All employees will be made aware of this policy and their obligations under it. Each team member will confirm their understanding of this policy annually. New employees will be briefed on this policy as part of their induction.

12. Risk assessment

The Scottish Shutter Company reviews its bribery and corruption risk annually. As of April 2026, our assessed risk remains low, based on the following factors:

We are a small to medium enterprise operating primarily in the domestic market within Scotland.
Our sector (home improvement and interior design) carries inherently low bribery risk.
We do not work with government contracts or public sector procurement.
Our business relationships are straightforward, involving direct dealings with customers and established suppliers.

Factors that could change this assessment include new supplier relationships, international procurement, or significant changes in business scope. This assessment will be reviewed again in April 2027.

13. Review

This policy is reviewed annually each April to ensure it remains relevant and effective. All employees will be made aware of any changes.

Signed: David Browne
Date: April 2026

Anti-Bribery & Corruption Policy