Anti-Bribery & Corruption Policy

Four Key is committed to conducting its business honestly, fairly and transparently. We have zero tolerance for bribery and corruption and are committed to complying with the Bribery Act 2010 and other applicable legal requirements.

Four Key provides property and block management services, including service charge budgeting and collection, building safety and statutory compliance, planned and reactive maintenance, and resident communication, for freeholders, landlords, developers, investors, build-to-rent operators and resident management and right to manage companies. Because our work involves handling client and leaseholder funds, appointing and paying contractors, and dealing with insurers, brokers, professional advisers and public bodies, we treat integrity as fundamental to the way we operate. This policy is endorsed by our directors, who are responsible for its implementation.

Bribery is a criminal offence. Under the Bribery Act 2010, a commercial organisation can itself be guilty of an offence if a person associated with it bribes another person intending to obtain or retain business or an advantage for the organisation, unless the organisation can show that it had adequate procedures in place to prevent bribery. This policy forms part of those procedures.

This policy applies to our directors, employees and others acting for or on behalf of Four Key. This includes consultants, agents, and temporary and part-time staff, and any other person who performs services for or on behalf of Four Key, whether or not they are paid. It applies to our dealings with both public officials and private persons. We expect contractors, suppliers, consultants and business partners to uphold equivalent standards in their dealings with us.

Four Key is responsible for the conduct of those who act on its behalf. Clients, directors of resident management and right to manage companies, leaseholders and independent contractors who do not act on Four Key's behalf remain responsible for their own compliance. Where we become aware of a concern involving any of them in connection with our services, we will consider it under this policy and take proportionate action, which may include raising it with the relevant client, ceasing to act where our agreement allows, or reporting it to the relevant authorities.

We prohibit offering, promising, giving, requesting, agreeing to receive or accepting a bribe, directly or through another person. A bribe can be money or any other benefit intended to induce or reward improper conduct. We also prohibit kickbacks, secret commissions and unofficial facilitation payments. The only exception is where a payment is made because of an immediate threat to a person's safety, health or liberty; in that case the payment must be reported to a director as soon as possible and accurately recorded.

The Bribery Act 2010 creates offences of giving or offering a bribe, requesting or receiving a bribe, bribing a foreign public official, and the failure of a commercial organisation to prevent bribery. A bribe can be any financial or other advantage, including cash, gifts, hospitality, loans, discounts, free or discounted work to a person's home or property, job offers or work experience, favours, and charitable or political donations. It makes no difference whether the benefit goes directly to the person concerned or to a relative, friend or business associated with them, or whether it is given or received through a contractor, agent or other intermediary.

Bribery of public officials, including officers of local authorities, building control bodies, fire and rescue services, the Building Safety Regulator and other regulators, is strictly prohibited. No benefit may be offered or given to a public official in connection with any inspection, application, approval, enforcement decision or other official act.

Gifts and hospitality must have a legitimate business purpose, be reasonable and proportionate, and never improperly influence a decision. Cash and cash equivalents are prohibited. Gifts or hospitality that could compromise impartiality, including during supplier selection or insurance placement, must be refused. Approval and recording requirements apply under our internal procedures.

Particular care applies to gifts and hospitality offered by or to contractors, suppliers, brokers, insurers, clients, leaseholders, residents and public officials, and during any tender, quotation exercise, statutory consultation, major works procurement, contract renewal, insurance claim or dispute, when they should normally be declined. Gifts and hospitality offered or received above a nominal value must be declared to a director, approved where required, and entered in a register of gifts and hospitality. Gifts of modest, customary or seasonal value may be accepted where they are transparent, infrequent and could not reasonably be seen as an inducement.

Political donations must not be made on behalf of Four Key. Charitable donations and sponsorships on behalf of Four Key require prior director approval, must be recorded, and must never be used as a means of obtaining an improper advantage.

Contractor and supplier decisions must be based on objective considerations such as suitability, competence, price, quality, safety and service. Personal benefits must never influence appointments or payments. Relevant personal, family, financial and business interests must be declared and managed, with disclosure and consent where required.

Appointments of contractors and suppliers for managed buildings will follow the procurement requirements of the relevant lease, management agreement and applicable law, including statutory consultation requirements for qualifying works and long-term agreements. Where appropriate we will obtain competitive quotations or tenders and keep a record of the basis for the decision. We do not split contracts, or manipulate specifications, quotations or tender processes, to avoid consultation, approval or competition requirements.

Directors, employees and consultants must declare any actual or potential conflict of interest to a director when it arises and when circumstances change, and declarations will be recorded. They must not hold an undeclared interest in, receive any payment or benefit from, or carry out paid work for, any contractor or supplier appointed to a building that Four Key manages. Where we are aware that a client, a director of a resident management or right to manage company, a developer, a freeholder or a leaseholder has an interest in a contractor or supplier, we will ensure that the interest is disclosed to the relevant decision-makers and recorded.

Four Key may be held responsible for bribery committed by those who perform services for or on its behalf, wherever they are based. We therefore carry out proportionate, risk-based due diligence before appointing contractors, suppliers, consultants, agents and other intermediaries, taking into account the nature and value of the services, any links to public officials and the circumstances of the appointment.

Where appropriate, our appointment terms include anti-bribery undertakings and the right to suspend or terminate for breach. We do not use third parties to do anything that we are prohibited from doing ourselves. Payments to third parties must be commensurate with the services provided, supported by a valid invoice, and made only to the named supplier's verified account.

Four Key may receive referral fees, commissions or other remuneration only where lawful and permitted under the relevant contractual and regulatory arrangements. Any such remuneration must be authorised, appropriately documented, accurately recorded and disclosed where required. Nothing in this policy creates or acknowledges any entitlement on the part of Four Key to receive or retain any commission, referral fee or other remuneration.

We will disclose fees, commissions and relevant conflicts when required by law, applicable regulatory rules, contractual obligations or the requirements of the relevant insurance principal. This includes transaction-specific information where required. Referral income must not result in unsuitable provider selection, concealed costs or improper disadvantage to clients or leaseholders.

Four Key does not select, recommend or place insurance, brokers or other providers by reference to the commission, fee or other benefit it may receive. Four Key will comply with all legal and regulatory restrictions on the receipt, retention or recovery of insurance-related commissions and remuneration affecting residential leasehold buildings, including the Leasehold and Freehold Reform Act 2024 and any regulations made under it, and applicable Financial Conduct Authority requirements, from the date on which those restrictions apply. Where permitted by law, insurance-related remuneration will be declared to clients as required and, where the law requires, to leaseholders. We will cooperate with insurers, brokers and regulators in responding to proper requests for information about commission and remuneration arrangements, subject to our confidentiality obligations.

We provide accurate and complete information to insurers, brokers, loss adjusters and surveyors. We do not offer, request or accept any benefit in connection with the placement of cover, the assessment of a claim or a valuation, and we do not make or support any false, exaggerated or misleading claim.

Staff and directors must not arrange undisclosed personal rewards. This policy does not grant permission to undertake regulated insurance activities. Any such activity must have the necessary lawful basis and remain within the scope of the relevant permissions or appointment.

We hold and apply service charge funds, reserve funds and other client money in accordance with applicable law, the relevant lease or management agreement and any applicable client money protection requirements. Payments from client or service charge accounts must be properly authorised, supported by a valid invoice or other documentation and evidence that the goods or services were supplied, and made by traceable means. Cash payments are not permitted.

We apply segregation of duties and, in proportion to risk and value, dual authorisation or equivalent controls over payments. We verify supplier bank details, and any request to change them, before payment. We do not make or accept payments that are false, inflated or unsupported, and we do not retain undisclosed rebates, discounts, commissions or mark-ups on contractor or supplier invoices. Any rebate, discount or commission received in connection with our services to a client will be accounted for in accordance with our management agreement and applicable law.

Our books and records must accurately reflect transactions. False or misleading entries, undisclosed accounts and the concealment of any payment are prohibited. We will not knowingly handle the proceeds of crime, and any suspicious payment, request or transaction must be reported to a director.

Our approach includes proportionate risk assessment, supplier and partner checks, payment controls, accurate records, staff awareness and oversight by our directors. We review our policy and procedures regularly and when material changes or concerns arise. Breaches may result in disciplinary or contractual action and referral to relevant authorities where appropriate. Serious breaches by employees may constitute gross misconduct.

Our directors are responsible for ensuring that this policy is implemented, communicated and supported by adequate resources. Our risk assessment takes account of, among other things, our dealings with contractors, suppliers, brokers and insurers, our handling of client and service charge funds, our use of intermediaries and our dealings with public bodies, and is updated when our business or risks change.

Directors, employees and consultants will be given proportionate guidance on this policy when they join or are engaged and at appropriate intervals afterwards, and relevant personnel are required to confirm that they have read and will comply with it. Proportionate pre-engagement checks are carried out for roles involving financial responsibility, subject to applicable law. We keep records, including registers of gifts and hospitality and of conflicts of interest, supplier due diligence records and records of concerns raised and action taken, for as long as required by law and our record-keeping procedures. We review this policy at least annually, and sooner following any significant incident or change in law or in our business.

Where bribery or corruption is suspected or identified, we will assess the concern promptly and, where appropriate, investigate or arrange for it to be investigated, take proportionate steps to prevent recurrence, cooperate with the police and other authorities and, where required by the terms of our insurance policies or contracts, notify our insurers and any affected clients.

Directors, employees and anyone acting on our behalf must report any offer or request of a bribe, and any actual or suspected breach of this policy, as soon as possible.

If you suspect bribery, corruption or an improper payment involving Four Key, please contact an unconflicted director. You can telephone 020 8050 4444 or write to a director at the address below. For help arranging contact, email info@fourkey.co.uk. This is a general contact address; please request a confidential conversation rather than sending sensitive allegations to a shared inbox.

If your concern involves the director you would usually contact, ask to speak to another director. Where internal reporting is unsafe or inappropriate, you may use an appropriate external reporting channel. External channels include the police, the Serious Fraud Office and other relevant regulators or prescribed persons. Nothing in this policy restricts lawful reporting to authorities or whistleblowing rights.

We will consider concerns fairly, protect confidentiality as far as reasonably possible and will not tolerate retaliation against anyone who raises a concern honestly or refuses to participate in bribery, even if their concern is not substantiated. No one will suffer demotion, penalty or other detriment for refusing to pay or accept a bribe, even if this results in a loss of business.

• Email: info@fourkey.co.uk
• Telephone: 020 8050 4444