Effective Date: 17/02/2026
Review Date: 16/02/2027
Policy Owner: Ed Smit, Founder & Managing Director

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1. Purpose

Here Now Films Ltd is committed to conducting business ethically, transparently, and in full compliance with all 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 recognise and avoid such conduct.

2. Scope

This policy applies to all individuals working for or on behalf of Here Now Films, including directors, employees (whether permanent, fixed-term, or part-time), contractors, freelancers, and any third party acting as an agent or representative of the company.

It applies to all business activities, in the UK and internationally, across all client engagements — including commercial productions, documentary projects, retainer work, and any other professional undertaking.

3. What Is Bribery?

Bribery is the offering, giving, soliciting, or receiving of any item of value as a means of influencing the actions of an individual holding a public or legal duty. Under the UK Bribery Act 2010, there are four key offences:

• Offering, promising, or giving a bribe (Section 1)
• Requesting, agreeing to receive, or accepting a bribe (Section 2)
• Bribing a foreign public official (Section 6)
• Failure by a commercial organisation to prevent bribery (Section 7)

A “bribe” does not have to be cash. It can include gifts, hospitality, favours, services, preferential treatment, or any other advantage offered with the intention of improperly influencing a decision.

4. Our Commitments

Here Now Films will:

• Conduct all business dealings with integrity and transparency.
• Not offer, promise, give, request, or accept bribes in any form.
• Not use third parties as a channel for bribery.
• Ensure that adequate procedures are in place to prevent bribery by anyone acting on the company’s behalf.
• Investigate any suspected breach of this policy promptly and thoroughly.
• Support and protect anyone who raises a genuine concern in good faith.

5. Gifts & Hospitality

Reasonable and proportionate hospitality and small gifts are a normal part of building professional relationships — particularly in the creative and media industries. However, they must never be offered or accepted with the intention of influencing a business outcome.

Acceptable examples: A modest working lunch with a client, a small gift at the end of a successful project, attendance at an industry event or screening.

Unacceptable examples: Lavish gifts or entertainment intended to secure or retain a contract, cash payments, gifts offered during a competitive pitch or procurement process, anything that would cause embarrassment if made public.

Guidelines:

• Gifts or hospitality above £100 in value (given or received) must be disclosed to the Managing Director and recorded in the Gifts & Hospitality Register.
• If in doubt about whether a gift or offer of hospitality is appropriate, seek guidance from the Managing Director before accepting or offering it.

6. Facilitation Payments

Here Now Films does not permit facilitation payments (small unofficial payments made to speed up routine government actions) under any circumstances. If you are asked to make such a payment, you should refuse and report it to the Managing Director immediately.

7. Third Parties & Suppliers

When engaging freelancers, subcontractors, fixers, or other third parties, Here Now Films will take reasonable steps to ensure those parties are aware of and comply with this policy. This includes:

• Communicating the policy to third parties working on our behalf where appropriate.
• Including anti-bribery provisions in contracts for significant engagements.
• Exercising due diligence when engaging new partners, particularly for international productions.

8. Political & Charitable Contributions

Here Now Films does not make political donations. Any charitable contributions made in the company’s name must be approved by the Managing Director and must not be used as a means of gaining improper business advantage.

9. Record Keeping

The company will maintain accurate financial records and ensure that all transactions are recorded transparently. No “off-the-books” accounts, undisclosed funds, or falsified records will be tolerated.

10. Responsibilities

Managing Director — Responsible for the overall implementation and enforcement of this policy, maintaining the Gifts & Hospitality Register, and ensuring compliance across the business.

All Team Members (employees, freelancers, contractors) — Responsible for reading and understanding this policy, acting in accordance with it, and raising any concerns promptly.

11. Reporting Concerns

If you suspect or become aware of any bribery or corruption — whether involving someone within Here Now Films or a third party — you should report it immediately to the Managing Director.

Reports can be made verbally or in writing. All reports will be treated seriously, investigated appropriately, and handled with discretion. No individual will suffer any detrimental treatment as a result of raising a genuine concern in good faith, even if it turns out to be mistaken.

If the concern involves the Managing Director, it should be reported to [Insert alternative contact — e.g. the company’s accountant or legal adviser].

12. Consequences of Breach

Any breach of this policy will be treated as a serious matter. For employees, this may result in disciplinary action up to and including dismissal. For freelancers and contractors, it may result in immediate termination of the engagement. Serious cases may also be reported to the relevant authorities.

13. Review

This policy will be reviewed annually or sooner if there are changes to legislation or the nature of the company’s work that require it. All team members will be notified of any significant changes.