​Last reviewed: 19th March 2026
Next review: 1 Jan 2027

Policy Owner: Samuel Davies, Managing Director, Atlas Media Limited
Contact: sam@atlas.film
 

1. Purpose

 

Atlas Media Limited is committed to conducting all business with integrity, transparency, and in full compliance with applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010.

 

This policy sets out the company’s position on bribery and corruption and provides guidance for all team members on how to identify, prevent, and avoid unethical conduct.

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2. Scope

 

This policy applies to all individuals working for or on behalf of Atlas Media Limited, including directors, employees (permanent, fixed-term, or part-time), freelancers, contractors, and any third parties acting as representatives of the company.

 

It covers all business activities in the UK and internationally, across client projects, commercial productions, documentaries, retainer work, and other professional engagements.

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3. What Constitutes Bribery

 

Bribery involves offering, giving, requesting, or receiving any item of value with the intention of improperly influencing the actions of an individual in a public, legal, or business role.

 

Under the UK Bribery Act 2010, key offences include:

 

• Offering, promising, or giving a bribe

• Requesting, agreeing to receive, or accepting a bribe

• Bribing a foreign public official

• Failing to prevent bribery within a commercial organisation

 

A bribe is not limited to cash and may include gifts, hospitality, favours, services, preferential treatment, or other advantages intended to influence a decision improperly.

 

4. Our Commitments

 

Atlas Media Limited will:

 

• Conduct all business dealings with honesty, integrity, and transparency.

• Not offer, promise, give, request, or accept bribes in any form.

• Avoid using third parties as a channel for bribery.

• Maintain procedures to prevent bribery by anyone acting on our behalf.

• Investigate suspected breaches promptly and thoroughly.

• Support and protect anyone who raises a genuine concern in good faith.

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5. Gifts and Hospitality

 

Modest and proportionate gifts or hospitality are part of normal business practice but must never be offered or accepted with the intention of influencing a business outcome.

 

Acceptable examples: Working lunches, small tokens at the end of a project, attendance at industry screenings or events.

 

Unacceptable examples: Lavish gifts or entertainment meant to secure or retain contracts, cash payments, gifts during competitive pitches, or anything that could cause reputational harm if disclosed publicly.

 

Guidelines:

 

• Gifts or hospitality valued over £100 must be recorded in the Gifts & Hospitality Register and disclosed to the Managing Director.

• When unsure, seek guidance from the Managing Director before offering or accepting anything.

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6. Facilitation Payments

 

Atlas Media Limited does not permit facilitation payments under any circumstances. Any request for such payments must be refused and reported to the Managing Director immediately.

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7. Third Parties and Suppliers

 

When working with freelancers, subcontractors, fixers, or other partners, the company will:

 

• Communicate this policy to third parties where relevant.

• Include anti-bribery provisions in contracts for significant engagements.

• Conduct due diligence on new partners, particularly for international projects.

 

8. Political and Charitable Contributions

 

Atlas Media Limited does not make political donations. Any charitable contributions made in the company’s name require prior approval from the Managing Director and must not be used to gain improper advantage.

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9. Record Keeping

 

Financial and business records must be accurate and transparent. Off-the-books accounts, undisclosed funds, or falsified records are strictly prohibited.

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10. Responsibilities

 

• Managing Director: Oversees the implementation and enforcement of this policy, maintains the Gifts & Hospitality Register, and ensures compliance.

• All Team Members (employees, freelancers, contractors): Responsible for understanding and complying with this policy, and promptly reporting any concerns.

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11. Reporting Concerns

 

Concerns about bribery or corruption should be reported immediately to the Managing Director, verbally or in writing, with as much detail as possible.

 

If the concern involves the Managing Director, it should be reported to an alternative contact (e.g. company accountant or legal adviser).

 

All reports are taken seriously, investigated appropriately, and handled confidentially. No individual will face detrimental treatment for raising a genuine concern in good faith, even if the concern proves unfounded.

 

12. Consequences of Breach

 

Any breach of this policy is treated seriously:

 

• Employees may face disciplinary action, up to and including dismissal.

• Freelancers and contractors may have their engagement terminated immediately.

• Serious breaches may be reported to the relevant authorities.

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13. Review

 

This policy will be reviewed at least annually or sooner if there are changes to legislation or company operations. All team members will be notified of any significant updates.