Last updated: 21 June 2026 — Version 1.0

This Anti-Bribery Policy sets out the position of OptiTech Automation — operated by Cristian Moise-Putanu, sole trader, Torquay, Devon, England — on bribery and corruption. It applies to Cristian Moise-Putanu personally and to any person acting on behalf of OptiTech Automation. This policy is published to demonstrate that adequate procedures are in place in accordance with section 7 of the Bribery Act 2010.

1. Our commitment

OptiTech Automation has zero tolerance for bribery and corruption. This applies to the operator, any agent or representative, and any person acting on behalf of OptiTech Automation in any capacity.

OptiTech Automation is committed to conducting all business with honesty, integrity, and in accordance with the law. We operate a zero-tolerance policy toward bribery and corruption in all their forms.

This commitment applies to:

Cristian Moise-Putanu as operator of OptiTech Automation
Any agent, contractor, consultant, or representative acting on behalf of OptiTech Automation
Any third party who acts in connection with our business or supply chain

Bribery and corruption are unlawful. A finding of bribery can result in criminal prosecution, unlimited fines, and reputational damage. We take this seriously regardless of the size of any amount involved or the seniority of the person involved.

2. What is bribery

Bribery is offering, giving, receiving, or requesting a financial or other advantage to induce or reward the improper performance of a function or activity. This includes facilitation payments — small payments to speed up routine government actions.

The Bribery Act 2010 creates four main offences:

Active bribery (s.1): Offering, promising, or giving a financial or other advantage to another person with the intention of inducing that person to perform a relevant function or activity improperly, or to reward them for doing so.
Passive bribery (s.2): Requesting, agreeing to receive, or accepting a financial or other advantage with the intention that a relevant function or activity will be performed improperly as a result.
Bribery of a foreign public official (s.6): Offering, promising, or giving a financial or other advantage to a foreign public official with the intention of influencing that official in their capacity as a public official, where doing so is intended to obtain or retain business or a business advantage.
Failure to prevent bribery (s.7): A commercial organisation commits an offence if a person associated with it bribes another person intending to obtain or retain business or a business advantage for the organisation. The only defence is that the organisation had adequate procedures in place to prevent such conduct. This policy is part of those adequate procedures.

A "financial or other advantage" is broadly defined and includes cash, gifts, hospitality, discounts, favours, services, loans, or any other benefit — whether given directly or indirectly, and whether given to the recipient or to another person on their behalf.

Facilitation payments: Facilitation payments are small payments made to officials to speed up or secure routine government actions (for example, obtaining a licence or permit). They are a form of bribery under the Bribery Act 2010 and are prohibited by this policy regardless of the amount involved. OptiTech Automation will not make facilitation payments in any jurisdiction.

3. Gifts and hospitality

Reasonable gifts and hospitality may be given or received where they are not intended to influence a business decision. Gifts over £25 in value must be declared. Cash gifts are never acceptable in any amount.

Gifts and hospitality can be a legitimate part of building business relationships. However, gifts and hospitality can also be used as a form of bribery. The following rules apply:

Low-value gifts (under £25): Gifts of modest value (under £25) may be given or received provided they are reasonable, appropriate to the relationship, not intended to influence a business decision, and not given at a time when a business decision is pending between the relevant parties.
Gifts over £25: Any gift or hospitality with an estimated value of £25 or more must be declared to Cristian Moise-Putanu immediately and recorded. Where a decision to accept or give such a gift is taken, the rationale must be documented.
Cash gifts: Cash gifts — including cash equivalents such as gift cards, vouchers, or cryptocurrency — are never acceptable regardless of the amount. This rule applies in both directions: we do not give or receive cash gifts in a business context.
Hospitality: Reasonable hospitality (meals, events) is acceptable where it is proportionate to the business relationship, not lavish, and not intended to influence a pending decision. Hospitality that is extravagant, one-sided, or timed to coincide with a procurement or contracting decision is not acceptable.

If you are uncertain whether a gift or hospitality is acceptable, the answer is to decline it (or not give it) and seek guidance.

4. Business relationships and third parties

We conduct due diligence on third-party providers before entering significant contracts. We do not make payments to agents or intermediaries contingent on securing contracts, and we do not engage suppliers who we have reason to believe engage in corrupt practices.

The Bribery Act 2010 can hold a commercial organisation responsible for the bribery of persons associated with it, including third-party contractors, agents, or intermediaries. We take the following steps to mitigate this risk:

Due diligence on providers: Before entering a significant commercial arrangement, we conduct proportionate due diligence on the prospective supplier or partner. For technology providers, we review their terms of service, privacy policy, and published compliance and ethics statements.
No contingent payments: We do not make payments to agents, consultants, or intermediaries that are contingent on or calculated by reference to securing a specific contract, customer, or regulatory approval. Commission structures that create an incentive to bribe are prohibited.
Contractual obligations: Where we engage contractors or agents in a role that involves interacting with third parties on our behalf, we will include anti-bribery obligations in the relevant contract or engagement terms.

If we become aware that a supplier or partner is engaged in bribery or corruption, we will end that relationship and, where appropriate, report it to the relevant authority.

5. Public officials and regulated bodies

Interactions with public officials — including local authority officers, HSE inspectors, Gas Safe Register personnel, and Home Office officials — are subject to heightened scrutiny. No payments or advantages of any kind may be given to a public official under any circumstances.

The Bribery Act 2010 applies heightened standards to interactions with public officials. A "public official" includes any person who holds a legislative, administrative, or judicial position; any person who exercises a public function; and any official or agent of a public international organisation.

In the context of our business, this includes (without limitation):

Local authority officers (planning, environmental health, licensing)
Health and Safety Executive (HSE) inspectors
Gas Safe Register personnel and officials
NICEIC, NAPIT, or other competent person scheme officials
Home Office officials (immigration compliance, right to work)
HMRC officers

No payment, gift, or advantage of any kind — however small — may be given to any public official in connection with our business. There are no exceptions to this rule. This prohibition applies even where such payments may be common practice in a particular country or context.

6. Reporting suspected bribery

Any suspected bribery or corruption connected to OptiTech Automation must be reported immediately. Whistleblowing protections apply under the Public Interest Disclosure Act 1998. We will not retaliate against anyone who raises a genuine concern in good faith.

If you suspect bribery, corruption, or a breach of this policy — whether by us, a supplier, a partner, or anyone acting on our behalf — you must report it immediately.

Reports should be made by email to: hello@optitechautomation.co.uk

All reports will be treated confidentially to the extent possible and will be investigated promptly.

Whistleblowing protections: A person who reports a genuine concern about bribery or corruption in good faith is protected from dismissal, detriment, or retaliation under the Public Interest Disclosure Act 1998. OptiTech Automation will not take any adverse action against any person who raises a genuine concern in good faith, even if that concern turns out to be unfounded after investigation.

If you are uncertain whether a situation constitutes bribery, seek guidance before acting. It is always better to ask than to proceed and discover later that you have breached this policy.

7. Consequences of breach

Confirmed bribery will be reported to the Serious Fraud Office or police and will result in immediate termination of the relationship with the person involved. There is no minimum threshold — any confirmed breach will be actioned.

We treat any confirmed breach of this policy with the utmost seriousness. The consequences of a confirmed breach are:

Criminal referral: We will report the matter to the Serious Fraud Office (SFO), the police, or such other authority as is appropriate, and will cooperate fully with any investigation or prosecution.
Termination of relationship: The business relationship with the person or organisation responsible for the breach will be terminated immediately. This applies whether the party involved is a supplier, contractor, agent, or any other person acting on behalf of or in connection with OptiTech Automation.
No minimum threshold: There is no minimum monetary value below which a breach of this policy will be overlooked. A facilitation payment of £5 is as much a breach as a payment of £50,000. We apply this policy consistently.

The Bribery Act 2010 provides for unlimited fines and up to ten years imprisonment for individuals convicted of bribery offences. We wish to be clear that compliance with this policy is not optional.

8. Review and contact

This policy is reviewed annually. It was approved by Cristian Moise-Putanu on 21 June 2026. The next review is due June 2027.

This policy is reviewed annually and updated as needed to reflect changes in law, business activities, or regulatory guidance.

This version was approved on 21 June 2026. The next scheduled review is June 2027.

Questions about this policy or requests for guidance on a specific situation should be directed to:

Cristian Moise-Putanu — Operator, OptiTech Automation

hello@optitechautomation.co.uk / Legal enquiries: legal@optitechautomation.co.uk

Anti-bribery policy