Anti Bribery Policy – Subcontractors
Reference: PS002/Subcontractor
Date: August 2026
POLICY:
Purpose – ServiceMaster Limited values its reputation for ethical behaviour and for financial integrity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation.
This document sets out the rules of the Business in relation to anti-bribery, fraud and corruption matters in the United Kingdom.
It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years’ imprisonment and/or a fine. As an employer if we fail to prevent bribery or fraudulent activities we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously.
In this policy, third party means any individual or organisation you come into contact with during the course of your work with us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians/political parties, other franchisees or their employees and employees of ServiceMaster Limited.
Conditions
This policy supports ServiceMaster Limited’s arrangements for preventing bribery, corruption and associated economic crime, including compliance with the Bribery Act 2010 and relevant provisions of the Economic Crime and Corporate Transparency Act 2023 (ECCTA).
This policy applies to all subcontractors, contractors, consultants, suppliers and other third parties engaged to provide services to, or on behalf of, ServiceMaster Limited or a ServiceMaster franchise business. It applies to all work undertaken on behalf of ServiceMaster Limited or a ServiceMaster franchise business, including local customer work, project work and National Account work.
Compliance
Compliance with this policy in relation to bribery and corruption is regarded as part of your obligations as a Subcontractor.
You are also required to train staff working in your subcontract business on the Anti-Bribery Policy and record the training as part of your staff records.
Individuals convicted of bribery offences may face imprisonment and/or a fine. Organisations convicted of failing to prevent bribery may face significant financial penalties and reputational damage. Separate criminal offences and corporate liabilities may arise under the Economic Crime and Corporate Transparency Act 2023.
Non-compliance with this Policy may result in withdrawal of National Account work, suspension of work, removal from approved contractor status, termination of contractual arrangements and, where appropriate, referral to the relevant authorities.
Policy
Bribery is the offer, promise, giving or receipt of any gift, loan, payment, reward or other advantage to or from any person as an inducement to act dishonestly, improperly or in breach of trust in connection with business activities carried out for ServiceMaster Limited or a ServiceMaster franchise business.
ServiceMaster Limited prohibits
subcontractors and anyone acting on their behalf:
the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement
to or from
any person or company, wherever they are situated and whether they are a public official or body or private person or company
by
any individual employee, agent or other person or body acting on behalf of either a ServiceMaster Franchise Business or on our behalf.
in order to
gain any commercial, contractual or regulatory advantage for any of the ServiceMaster franchised Brands in a way which is unethical
or in order to
gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual
Corruption is the abuse of your entrusted power or position for private gain.
Fraud is an offence which occurs when a person dishonestly makes a false representation in order to gain for themselves, a company or cause loss to another.
Further Clarification
This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the ServiceMaster business or of the person or body employing them or whom they represent.
This policy is not meant to prohibit the following practices providing they are customary, are proportionate and are properly recorded:
- normal and appropriate hospitality
- the giving of a ceremonial gift on a festival or at another special time
- the offer of resources to assist the person or body to make the decision more efficiently provided that they are supplied for that purpose only.
Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to ServiceMaster Limited before proceeding.
FACILITATION PAYMENTS AND KICKBACKS
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.
Facilitation payments, also known as “back-handers” or “grease payments”, are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in the UK, but are common in some other jurisdictions
Kickbacks are typically payments made in return for a business favour or advantage.
You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should ensure your staff are aware of the appropriate manager within your business to raise these with.
GIFTS, HOSPITALITY AND EXPENSES
We discourage Sub-Contractors from accepting or giving gifts or hospitality. We accept that the occasional modest giving and acceptance of gifts and hospitality may be a legitimate contribution to good business relationships. However, it is essential that they do not influence, nor could be perceived as influencing, business decision making. We must all consider whether the giving or receiving of a gift or hospitality is appropriate and ensure that they are given and received openly and without any attempt to mislead or hide their nature, value, purpose, or identity of the giver and recipient.
This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:
(a) establishing or maintaining good business relationships;
(b) improving or maintaining our image or reputation; or
(c) marketing or presenting our products and/or services effectively.
The giving and accepting of gifts is allowed if the following requirements are met:
(d) it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
(e) it does not include cash or a cash equivalent (such as gift certificates or vouchers);
(f) it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas;
(g) it is given openly, not secretly; and
(h) it complies with any applicable local law.
Promotional gifts of low value such as branded stationery to or from existing customers, suppliers and business partners will usually be acceptable.
Reimbursing a third party’s expenses, or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable.
The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. The intention behind it should always be considered.
Subcontractors must maintain proportionate arrangements for the approval and recording of gifts, hospitality and business expenses and must make evidence of such arrangements available to ServiceMaster Limited on reasonable request.
Subcontractors Responsibility
The prevention, detection and reporting of bribery is the responsibility of all Subcontractors
and their employees throughout their company. Subcontractors can report confidentially any suspicion of bribery to the Administration Manager at ServiceMaster.
Employees of Subcontractor business must be allowed to report confidentially any suspicion of bribery to the Subcontractor or their line manager.
No person shall be subjected to retaliation or detrimental treatment for refusing to participate in bribery or corruption or for reporting a genuine concern in good faith.
You should at all times act in accordance with the following provisions:-
- behave honestly, be trustworthy and set a good example;
- use the resources of the business in the best interests of the business and do not misuse those resources;
- make a clear distinction between the interests of the business and your private interests to avoid any conflict of interest, and if such conflict does arise you should report it to the ServiceMaster Limited Administration Manager immediately;
- ensure that any community support, sponsorship and charitable donations do not constitute bribery, and if in doubt you should consult ServiceMaster Limited immediately;
- confidentially report any incidents, risks and issues which are contrary to this policy document ServiceMaster Limited immediately;
- do not offer or accept bribes under any circumstances;
- have appropriate internal controls in place which will evidence the business reason for making or receiving payments to/from third parties; and keep a record of any reports of suspected bribery incidents;
- All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
The Subcontractor must ensure that all personnel engaged in delivering services on behalf of ServiceMaster Limited or a ServiceMaster franchise business receive appropriate anti-bribery and corruption training and that records of such training are maintained.
Where the Subcontractor engages employees, agency workers or lower-tier subcontractors in connection with ServiceMaster work, the Subcontractor must take reasonable steps to ensure that such persons comply with the requirements of this Policy.
This policy has been authorised by Alan Lewin, Managing Director, ServiceMaster Ltd
