KAI DESIGN LTDBusiness Ethics Policy

Effective Date: April 2025

1. Purpose

KAI DESIGN LTD (“the Company”) is committed to conducting its business with integrity, transparency, and in full compliance with all applicable laws and regulations. This Business Ethics Policy sets out the Company’s commitment to lawful and ethical conduct, with a specific focus on preventing corruption, bribery, fraud, and extortion.

2. Scope

This policy applies to all employees, officers, directors, contractors, consultants, and any third parties acting on behalf of KAI DESIGN LTD, regardless of their location.

3. Compliance with Applicable Laws

All personnel must comply with all applicable laws, rules, and regulations of the United Kingdom and any other jurisdiction in which the Company operates. These include, but are not limited to:

  • The Bribery Act 2010
  • The Fraud Act 2006
  • The Companies Act 2006
  • Relevant anti-money laundering regulations
  • Any other applicable industry-specific regulatory requirements

Ignorance of the law is not an excuse, and employees are expected to seek guidance if they are unsure of the legal or ethical implications of their actions.

4. Anti-Corruption and Anti-Bribery

KAI DESIGN LTD has zero tolerance for any form of bribery or corruption. This includes:

  • Offering, promising, giving, or accepting any undue advantage to influence a decision or secure an improper business advantage
  • Facilitating payments (“grease payments”) to expedite routine services
  • Offering or accepting kickbacks or other unethical incentives

Employees must not engage in any activity that might be perceived as bribery or an attempt to improperly influence a decision-maker.

5. Fraud Prevention

The Company is committed to identifying and preventing all forms of fraud. Fraud includes, but is not limited to:

  • Misrepresentation of facts
  • Forgery or alteration of documents
  • Misuse of Company assets or resources
  • False expense claims or financial reporting

Employees must report any suspected fraud immediately through the appropriate internal reporting channels.

6. Prohibition of Extortion

KAI DESIGN LTD strictly prohibits any form of extortion or coercion. No employee or representative shall use their position to intimidate, threaten, or coerce any individual or organisation for personal or corporate gain.

7. Reporting Violations

All employees are encouraged to report any suspected violations of this policy in good faith and without fear of retaliation. Reports may be made to:

  • The line manager or supervisor
  • The Human Resources Department
  • A designated Compliance Officer
  • [Insert details of any whistleblowing or ethics hotline, if applicable]

8. Disciplinary Action

Any breach of this policy may result in disciplinary action, up to and including termination of employment or contract. In cases of criminal conduct, the Company will cooperate fully with law enforcement authorities.

9. Policy Review

This policy will be reviewed annually and updated as necessary to ensure continued compliance with legal obligations and best practices.

Approved by:

 Michaela Reysenn, Founder
 Date: April 2025