Code of Ethics and Anti-Bribery Policy

1. Mission and Values

Classroom365 Limited operates with honesty, integrity, fairness and transparency.

This policy sets the standard for how we interact with colleagues, school clients, suppliers, contractors, business partners and other stakeholders.

All staff and contractors are expected to act professionally, avoid conflicts of interest and uphold Classroom365’s ethical standards when carrying out work on behalf of the Company.

2. Anti-Bribery and Corruption

In accordance with the Bribery Act 2010, Classroom365 maintains a zero-tolerance approach to bribery, corruption and improper business advantage.

Staff and contractors are strictly prohibited from offering, promising, giving, requesting or accepting any bribe, inducement, reward, facilitation payment or improper financial advantage.

This includes any payment, gift, favour, hospitality or benefit intended to influence a business decision, secure preferential treatment or improperly obtain or retain business.

3. Gifts and Hospitality

Genuine hospitality or small seasonal gifts may be accepted or offered only where they are:

  • transparent;
  • proportionate;
  • infrequent;
  • lawful;
  • not cash or cash equivalent;
  • not intended to influence a business decision;
  • not likely to create a conflict of interest or reputational concern.

Any gift or hospitality valued at over £25 must be recorded in the Company Gift Register held by the Office Manager.

Cash, vouchers, personal payments, excessive hospitality or gifts that could appear to influence a procurement, sales or supplier decision must not be accepted or offered.

4. Conflict of Interest

All personnel must avoid situations in which personal interests could conflict with, or appear to conflict with, their professional duties.

Any actual, potential or perceived conflict of interest involving a client, school, supplier, contractor, competitor, employee or family connection must be disclosed to the Board of Directors or Senior Management Team as soon as it is identified.

Where appropriate, conflicts will be recorded and managed through agreed actions, such as removing an individual from a purchasing, recruitment or decision-making process.

5. Professionalism, Equality and Respect

Classroom365 expects all staff and contractors to act professionally and respectfully in all business dealings.

We uphold the principles of our Equal Opportunities & Non-Discrimination Policy in all professional relationships.

We do not tolerate harassment, bullying, discrimination, victimisation or abusive conduct.

Staff are expected to treat colleagues, school clients, pupils, visitors, suppliers and business partners with dignity and respect.

6. Whistleblowing and Reporting Concerns

Classroom365 encourages an open and transparent culture where concerns can be raised safely.

If any employee, contractor or business partner suspects a breach of this policy, including bribery, corruption, fraud, financial impropriety, conflict of interest or unethical conduct, they should report it to the Office Manager, Senior Management Team or a Director.

Reports made in good faith will be treated seriously and as confidentially as possible.

Classroom365 will not tolerate retaliation, victimisation or detrimental treatment against anyone who raises a genuine concern in good faith.

7. Compliance and Accountability

Compliance with this policy is a condition of employment and, where applicable, contract.

Breaches of this policy may be treated as misconduct. Serious breaches, including bribery, fraud, corruption, deliberate concealment of conflicts of interest, or retaliation against a whistleblower, may constitute gross misconduct and could result in summary dismissal and/or legal action, subject to a fair disciplinary process.

Where disciplinary action is considered, Classroom365 will follow a fair process in line with relevant employment guidance.

Where appropriate, concerns may also be reported to relevant authorities.

8. Records and ISO Evidence

Records relating to this policy will be handled securely and in line with our Privacy Policy and Data Protection Policy.

Evidence may include:

  • gift and hospitality register entries;
  • conflict of interest declarations;
  • whistleblowing or concern records;
  • investigation records;
  • disciplinary records;
  • staff training or policy acknowledgement records;
  • supplier review records;
  • internal audit findings;
  • management review notes;
  • corrective action records.

9. Review and Approval

This policy is reviewed annually or sooner where there are significant changes to legislation, business operations, customer requirements, supplier risk or ISO management system requirements.

This policy has been reviewed and approved by the Board of Directors of Classroom365 Limited.

Document control
Version: 4.0
Last reviewed: May 2026
Next review due: May 2027
Approved by: Board of Directors
Policy owner: Classroom365 Limited