Last updated: 5 May 2026.
Ortent Advisory Ltd ("Ortent", "we", "us") operates with a zero-tolerance policy towards bribery and corruption in any form. This policy sets out the commitment Ortent makes, the standards that apply to those acting on our behalf, and the procedures we follow to comply with the UK Bribery Act 2010 and equivalent legislation in any jurisdiction in which we work.
1. Scope
This policy applies to every person performing services for or on behalf of Ortent, including the Principal, sub-contractors, advisors, and any third party engaged to act on Ortent's behalf. It applies in every country and territory in which Ortent does business.
2. What is prohibited
- Offering, promising, giving, soliciting or accepting any bribe — meaning a financial or other advantage intended to induce or reward improper conduct.
- Facilitation payments to public officials, regardless of local custom or expectation.
- Kickbacks of any form to or from clients, suppliers, partners or referrers.
- Hospitality, gifts or entertainment that are excessive in scale, lack a clear business purpose, or are designed to influence a procurement, hiring, or commercial decision.
- Charitable or political donations made to secure or retain business or any improper advantage.
3. Standards we hold ourselves to
- Modest, transparent hospitality only. Reasonable business hospitality (a meal, a coffee, a conference attendance) that is proportionate to the relationship and openly recorded is acceptable. Anything beyond that is not.
- No payments to win business. Ortent wins work on the merits of the engagement and the operator credibility of the principal, never on payments or inducements.
- Conflicts disclosed. Where a personal, financial or relational interest could plausibly influence judgement, we disclose it to the client at the outset of the engagement.
- Public officials. Any contact with public officials in connection with Ortent's work is conducted transparently and in compliance with the Bribery Act and applicable local law.
4. Procedures
- Engagement letters. Every engagement is documented in writing with clearly stated fees, scope and deliverables. Ortent does not work on undocumented or off-contract terms.
- Supplier and sub-contractor due diligence. Suppliers and sub-contractors are selected on capability, reputation and contractual transparency. Any supplier asking for or offering off-contract payments is disengaged immediately.
- Records. Hospitality given or received is recorded in our internal log where it exceeds nominal value. Books and records are maintained accurately and reflect the true nature of every transaction.
- Training and awareness. Anyone acting on Ortent's behalf is briefed on this policy at the start of their engagement.
5. Reporting concerns
If you suspect a breach of this policy, by Ortent or by anyone acting on our behalf, raise it via our contact form or directly to legal@ortent.co. Concerns will be reviewed by the Principal and appropriate action will be taken. Ortent will not retaliate against anyone who raises a concern in good faith.
6. Review
This policy is reviewed annually by the Principal of Ortent Advisory Ltd, and updated as needed. Material updates are noted at the top of the page.
Andrew Wyatt
Principal, Ortent Advisory Ltd