CUDO Ventures Limited
Version dated: 11 December 2025
Ethics policy
Purpose
This policy sets out our organization’s commitment to conducting business ethically, responsibly, and in full compliance with UK law. It provides a framework for expected standards of behaviour, decision-making, and accountability. By embedding ethical principles into our culture, we aim to build trust with employees, customers, suppliers, regulators, and the wider community.
Scope
This policy applies to:
- All employees, contractors, agency workers, and temporary staff.
- All suppliers, partners, consultants, and third parties engaged with our organization.
- All business activities conducted in the UK and internationally, regardless of location or function.
Principles of ethical conduct:
Integrity and honesty
- Employees must act with honesty, fairness, and transparency in all business dealings.
- Conflicts of interest must be declared and managed appropriately (e.g., personal relationships with suppliers).
- Fraud, corruption, or deception will not be tolerated under any circumstances. Please refer to our anti-corruption & bribery policy for further detail.
- All financial reporting must be accurate, complete, and compliant with accounting standards.
Respect for people
- We are committed to diversity, equity, and inclusion, ensuring equal opportunities for all.
- Harassment, bullying, or discrimination of any kind is prohibited.
- We respect human rights and uphold fair labour practices, including freedom of association and fair pay.
- We promote a culture of dignity, respect, and collaboration in the workplace.
Anti-bribery and corruption
- We maintain a zero-tolerance approach to bribery and corruption.
- Employees must not offer, give, solicit, or accept bribes or improper advantages.
- Hospitality and gifts must be proportionate, transparent, and recorded in line with company policy.
- Facilitation payments (small payments to speed up routine processes) are strictly prohibited.
Please refer to our anti-corruption & bribery policy for further detail.
Confidentiality and data protection
- Employees must protect confidential information, including trade secrets, IP, client data, and employee records.
- Personal data must be handled lawfully, fairly, and securely, in line with UK GDPR.
- Breaches of confidentiality or data protection obligations will be investigated and may result in disciplinary action.
- Cybersecurity awareness training will be provided to all staff.
Environmental responsibility
- We are committed to minimising our environmental impact.
- Employees should act responsibly in relation to energy use, waste reduction, and sustainable practices.
- We will comply with environmental legislation and seek opportunities to improve sustainability.
Fair competition
- We support free and fair competition and comply with UK competition law.
- Anti-competitive behaviour, including collusion, price-fixing, or abuse of market position, is prohibited.
- Employees must avoid practices that could damage the integrity of markets or mislead customers.
Responsible use of company resources
- Company assets, including IT systems, vehicles, and funds, must be used responsibly and for legitimate business purposes.
- Misuse of resources, including theft, fraud, or unauthorised personal use, is prohibited.
- Intellectual property must be respected and protected.
Responsibilities
- Board and Senior Management: Ensure ethical standards are embedded in strategy, culture, and governance.
- Managers: Lead by example, communicate expectations, and ensure teams understand and comply with this policy.
- Employees: Act in line with this policy, complete required training, and raise concerns if they witness unethical behaviour.
- Suppliers and Partners: Required to comply with our ethical standards and demonstrate responsible practices.
Reporting concerns
- Employees can report concerns confidentially through our whistleblowing procedure.
- Reports will be investigated promptly, fairly, and confidentially.
- Whistleblowers will be protected from retaliation.
Training and awareness
- All employees will be required to read our Ethics Policy and can raise any queries with a member of the People Team.
Monitoring and review
- This policy will be reviewed annually to ensure compliance with UK legislation and best practice.
- Internal audits will monitor adherence to ethical standards.
- Feedback from employees, customers, and partners will be used to refine and strengthen our approach.
Continuous improvement
- We recognize that ethics is an evolving area and commit to regularly updating our practices.
- Emerging issues such as digital ethics, AI governance, and climate responsibility will be incorporated into our strategy.
Breach of policy
- Breaches of this policy may result in disciplinary action, up to and including dismissal.
- Breaches by suppliers or partners may result in termination of contracts or partnerships.
- Serious breaches may be reported to regulators or law enforcement authorities.