MBR Mobility Advisory Ltd will conduct its consultancy work honestly, independently, and fairly. This policy applies to the Director and anyone delivering services on MBR’s behalf, including associates, subcontractors, and intermediaries. It covers public and private sector work in the UK and overseas.

Prohibited conduct

We prohibit offering, promising, giving, requesting, or accepting bribes, kickbacks, or improper advantages. Facilitation payments are prohibited. Nobody may use a third party, charitable contribution, referral arrangement, or personal payment to do indirectly what MBR would not do itself. We will not offer employment, confidential information, or a commercial benefit to influence a procurement decision improperly.

Where a threat to immediate personal safety forces a payment, the person should prioritise safety and report the circumstances promptly so that advice and appropriate reporting can follow.

Gifts hospitality and expenses

Gifts and hospitality must have a legitimate business purpose, be modest, lawful, transparent, and proportionate, and comply with the recipient organisation’s rules. Cash and cash equivalents are prohibited. No gift or hospitality may be offered or accepted to influence a live tender, supplier assessment, or contract award. Travel and accommodation must be justified and documented.

All offered or received gifts and hospitality, including declined offers where relevant, will be recorded. Associates must seek the Director’s prior written approval. The Director will record the purpose and assess propriety before proceeding; sensitive cases require independent professional advice. There is no automatic safe monetary threshold.

Independence and conflicts

Before accepting work and when circumstances change, we will assess actual, potential, and perceived conflicts. Examples include advising competing bidders, evaluating a supplier with which we have a financial relationship, personal connections to decision makers, and using one client’s confidential information for another.

We will disclose material conflicts to the relevant client without breaching another party’s confidentiality, agree written safeguards where the conflict can properly be managed, and decline or stop work where it cannot. Client consent does not legitimise unlawful conduct. Supplier commissions and referral fees must be disclosed and agreed before an engagement proceeds; they must never compromise impartial advice.

Due diligence and records

Checks will be proportionate to geography, sector, procurement exposure, and intermediary risk. We will verify business identity, competence and the commercial purpose of payments, examine warning signs and use appropriate contractual obligations. Payments require a genuine service, an accurate invoice and a verified payee. Unusual bank changes will be checked through a separate trusted channel.

The Director will maintain gifts, hospitality and conflicts records and document approval, safeguards and decisions. Records will be retained under MBR’s retention arrangements.

Reporting and response

Report concerns to enquiries@mbrmobilityadvisory.com marked Confidential ethics concern. If the Director is implicated, seek independent legal advice or report to an appropriate authority. Good faith reports will not attract retaliation. Confidentiality will be protected so far as practicable, without promising absolute secrecy.

MBR will assess allegations, preserve evidence, and seek advice. Responses may include corrective action, removal from an assignment, contractual remedies, and reporting to authorities. The Director will review this policy annually and provide risk-appropriate briefing before sensitive assignments.