1. Why this policy exists
[ENTITY NAME] (“we”, “us”, “our”), which operates FranchiseMapp, has zero tolerance for bribery and corruption, and for facilitating tax evasion, in any part of our business. This policy sets out what that means in practice, who it applies to, and the procedures we have in place to prevent it — the Bribery Act 2010 and the Criminal Finances Act 2017 both make an organisation liable for the acts of people connected to it unless it can show it had reasonable procedures in place to stop this. This document, together with the disclosure and due-diligence steps described in it, is that answer.
2. Who this applies to
This policy applies to us, our staff, and to everyone taking part in the FranchiseMapp Referral Scheme (Referrers, consultants, brokers and other introducers) in connection with the Scheme. Referral Scheme §12 already requires Referrers to follow this policy and the wider law; this page is what that section points to.
3. What counts as bribery, in this context
A bribe is any financial or other advantage offered, promised, given, requested or accepted to induce or reward someone doing their job improperly — including a franchise consultant recommending FranchiseMapp to a client while being paid to do so without saying so. The commercial shape we specifically guard against is a secret or undisclosed commission: a referred franchisor who does not know their adviser is being paid to recommend us cannot properly weigh that advice, and an undisclosed commission is, in substance, the thing this law exists to catch.
That is why disclosure sits at the centre of how the Scheme actually runs, not only in this policy: we tell every referred franchisor ourselves, in our own Terms of Service, that their consultant may be earning commission from us — a commission the payer has disclosed is not a secret one. Referral Scheme §11 separately requires the Referrer to confirm, at the point of referral, that they have made their own disclosure where their own professional or contractual obligations require it.
4. Facilitation of tax evasion
Separately from bribery, the Criminal Finances Act 2017 makes us liable if someone associated with us criminally facilitates UK or foreign tax evasion, unless we had reasonable prevention procedures in place. Referral Scheme §12.2 already requires Referrers not to evade, or help anyone evade, tax. We do not advise Referrers on their own tax position, structure payments in a way designed to help anyone conceal income, or knowingly continue paying commission to someone we have reason to believe is using it to evade tax.
5. Our procedures
These are the specific, proportionate steps we take — proportionality matters here: the Scheme is a straightforward, published-rate commission arrangement with individual introducers, not a high-risk international sales operation, and our procedures are sized to that actual risk rather than copied from a template built for a different kind of business.
- Top-level commitment. This policy is approved and owned at the same level that owns the Referral Scheme itself, and its zero-tolerance position is stated directly in this document, not delegated to a code of conduct nobody reads.
- Risk assessment.The Scheme’s specific risk is an undisclosed commission distorting a referred franchisor’s decision — a recognised risk profile for any commission-paid introducer arrangement, and the one this policy and Referral Scheme §11 are built around. We do not operate in, or pay commission in connection with, jurisdictions carrying materially higher bribery or facilitation risk than the UK.
- Due diligence.Referral Scheme §2.1 already asks anyone joining the Scheme for identity and business evidence before they can start earning commission — the natural point to also screen for anything that would make this policy’s risk materially worse for a particular Referrer.
- Communication.This policy is linked from Referral Scheme §12.3, reachable from the Scheme’s footer, and every consultant is expected to read it as part of accepting the Referral Scheme terms. Not yet built: a separate, positive acknowledgement of this specific policy at signup, distinct from accepting the terms as a whole — logged as outstanding below.
- Monitoring and review. We review this policy at least annually, and immediately after any concern raised under section 6 below or any material change to how the Scheme operates.
6. Raising a concern
If you become aware of anything that might breach this policy — whether you are a Referrer, a franchisor, or a member of our own team — tell us straight away at [email protected]. We take every report seriously and will not penalise anyone for raising a genuine concern in good faith.
7. What happens if this policy is broken
A Referrer who breaches this policy, or Referral Scheme §12, can have their participation in the Scheme ended immediately and any unpaid commission withheld or reversed, under Referral Scheme §§8 and 17.3. Depending on what happened, we may also be obliged to report it to the relevant authorities. This policy is reviewed at least once a year, and sooner if a report under section 6 or a change to the Scheme suggests it should be.
Contact us
Questions about this policy: [email protected]
This is a first-pass draft, written to describe procedures that are genuinely in place or genuinely committed to — not template language. It has not yet been reviewed by a solicitor and should not be relied on as a complete s.7(2)/Criminal Finances Act 2017 defence until it has been. [ENTITY NAME], registered in England and Wales, company number [company number], registered office [address]. Placeholder — fill in before publishing.