Anti-bribery and Money Laundering Policy

1. Introduction

Huntley Care Limited (“Huntley Care”, “we”, “our”, “us”) is committed to conducting all business in an ethical and transparent manner, in full compliance with:

• The UK Bribery Act 2010;

• Applicable EU anti-corruption directives;

• Maltese anti-money laundering legislation, including the Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR).
   

This Policy outlines our zero-tolerance approach to bribery, corruption, and money laundering.

2. Scope

This Policy applies to:

• All employees, directors, contractors, and temporary staff;

• All agents, consultants, suppliers, and business partners acting on behalf of Huntley Care;

• All operations and transactions in the UK, Malta, or any jurisdiction in which Huntley Care operates.

3. Anti-Bribery Commitment

Huntley Care prohibits:

Offering, promising, giving, or authorising a bribe or facilitation payment;

• Soliciting, accepting, or receiving a bribe in any form, whether monetary or non-monetary;

• Engaging in conduct that could be perceived as corrupt or unethical.
   

All staff are required to act with integrity and report any suspected bribery or corruption immediately.

4. Anti-Money Laundering Commitment

Huntley Care is committed to preventing its services or resources from being used for money laundering or terrorist financing.

Employees must:

• Undertake customer due diligence where appropriate;

• Monitor transactions for suspicious activity;

• Report any suspicious transactions to the Compliance Officer in accordance with UK and Maltese law.

5. Responsibilities

All employees and partners are responsible for:

• Understanding and complying with this Policy;

• Avoiding conduct that could breach anti-bribery or anti-money laundering regulations;

• Reporting any concerns or violations through the internal reporting channels.
   

Non-compliance may result in disciplinary action, termination, and possible civil or criminal liability.

6. Gifts and Hospitality

Employees may only accept or give gifts or hospitality that are:

• Modest, reasonable, and proportionate;

• Fully recorded and authorised in accordance with Huntley Care procedures;

• Never intended to influence business decisions improperly.

7. Reporting and Whistleblowing

Concerns regarding bribery, corruption, or money laundering should be reported immediately to:

UK: +4420 8049 1767

Malta: +356 276 33319

Email: complaints@huntleycare.com

Reports may be made confidentially and without fear of retaliation.

8. Training and Monitoring

• Huntley Care will provide mandatory training to staff on anti-bribery and anti-money laundering requirements.
  Regular audits and reviews will ensure compliance with this Policy and relevant legislation.