Anti-Bribery, Corruption and Fraud Policy 

CEO Statement of Commitment 

At Micheldever Tyre Services Limited, integrity, accountability and responsible business conduct are fundamental to the way we operate. As a subsidiary of Sumitomo Rubber Industries, Ltd., we are committed to conducting business honestly, transparently and in accordance with the laws and standards that apply to us.

We maintain zero tolerance for bribery, corruption and fraud. We recognise that misconduct can arise through the actions of employees, senior managers, agents, subsidiaries and other associated persons. We therefore expect everyone who works for, represents or does business with us to act ethically, identify risks and speak up when something does not appear right.

This statement confirms our commitment for 2026 and supports our Anti-Bribery, Corruption and Fraud Policy, related financial controls and the Sumitomo Rubber Industries, Ltd. compliance framework. We will continue to assess our risks, strengthen proportionate prevention measures and respond appropriately to concerns.


 

Graham Mitchell

Chief Executive Officer

Micheldever Tyre Services Limited

29th September 2026

Our Aim

• To prevent, detect and respond to bribery, corruption and fraud across our operations and business relationships.

• To maintain adequate procedures to prevent bribery under the Bribery Act 2010 and reasonable fraud prevention procedures under the Economic Crime and Corporate Transparency Act 2023.

• To ensure employees and relevant third parties understand the standards expected of them and their responsibility to raise concerns.

• To protect our customers, colleagues, business partners, shareholders and reputation through effective governance, training and controls.

Our Scope

• All directors, officers and employees of Micheldever Tyre Services Limited, including permanent, temporary and agency workers.

• Third parties acting for or on behalf of Micheldever Tyre Services Limited, including agents, consultants, intermediaries, contractors, distributors, suppliers and other business partners.

Key Definitions 

• Bribery: Offering, promising, giving, requesting or accepting a financial or other advantage where this is intended to induce, reward or result in the improper performance of a relevant function or activity.

• Corruption: The abuse of entrusted power or position for private or improper benefit. It includes bribery and other conduct that compromises impartial or lawful decision-making.

• Fraud: Dishonest conduct intended to make a gain, cause a loss or expose another person or organisation to a risk of loss. This includes false representation, failing to disclose information where there is a legal duty to do so, and abuse of position.

Our Commitments

In line with the Bribery Act 2010, the Fraud Act 2006, the Economic Crime and Corporate Transparency Act 2023 and applicable Sumitomo Rubber Industries, Ltd. policies, we make the following commitments.

Zero Tolerance

We do not tolerate bribery, corruption, fraud, facilitation payments, false accounting or the deliberate concealment of improper conduct. Suspected breaches will be assessed and investigated. Confirmed breaches may lead to disciplinary action, dismissal, termination of contract, recovery action or referral to law enforcement or regulatory authorities.

Ethical Culture and Tone from the Top

Our Board and Senior Management are responsible for promoting integrity and ensuring that ethical conduct is reflected in business decisions, incentives and controls. Managers must lead by example and create an environment in which concerns can be raised without fear of retaliation.

Adequate and Proportionate Procedures

We maintain prevention procedures that are proportionate to the nature, scale and complexity of our activities and the risks we face. These procedures include risk assessment, due diligence, financial and non-financial controls, communication, training, monitoring and review. For fraud, our approach reflects the six principles in the statutory guidance: top-level commitment, risk assessment, proportionate risk-based procedures, due diligence, communication, and monitoring and review.

Fraud Prevention and Financial Integrity

We assess fraud risk from the perspective of misconduct intended to benefit Micheldever Tyre Services Limited or, where relevant, a client. We maintain accurate books and records, appropriate approval authorities, segregation of duties and controls over payments, rebates, credits, expenses and other higher-risk transactions. No employee or associated person may create or approve false, misleading or incomplete records.

Training and Awareness

We provide proportionate, role-based training and regular communications to employees, managers and relevant third parties. Mandatory training covers bribery, corruption and fraud risks, gifts and hospitality, conflicts of interest, third-party engagements, accurate record keeping and how to report concerns. Training and awareness activity is reviewed in response to changes in risk, law and business operations.

Gifts, Hospitality, and Conflicts of Interest

Gifts and hospitality must be reasonable, proportionate, transparent and for a legitimate business purpose. They must never be offered, promised, given or accepted to improperly influence a decision or secure an improper advantage. Gifts or hospitality above £50 must be declared and, where required, approved and recorded in accordance with the Gifts and Hospitality Policy. Actual, potential or perceived conflicts of interest must also be disclosed promptly.

Third-Party Conduct and Due Diligence

We apply proportionate, risk-based due diligence before appointing and while working with relevant third parties. Higher-risk relationships may require enhanced checks, approvals, contractual protections, payment controls and ongoing monitoring. Third parties are expected to comply with applicable law and our standards, and to raise concerns relating to work undertaken for or on our behalf.

Reporting and Whistleblowing

We encourage employees and external stakeholders to report concerns promptly through management, the appropriate internal function or our independent whistleblowing service, Safecall, at www.safecall.co.uk/report/ or 0800 915 1571. Reports may be made confidentially and, where permitted, anonymously. Retaliation against anyone who raises a concern in good faith is prohibited. Allegations will be handled fairly, promptly and proportionately, with appropriate cooperation with law enforcement, regulators and other authorities.www.safecall.co.uk/report/

Record Keeping and Transparency

We maintain records that accurately and fairly reflect transactions, approvals and business relationships. This includes records relating to payments, expenses, discounts, rebates, commissions, charitable or political contributions, sponsorships, third-party due diligence, gifts and hospitality, conflicts of interest, investigations and remedial action. Off-book accounts, false descriptions and the concealment or destruction of relevant records are prohibited.

Monitoring and Continuous Improvement

The Risk Committee will review this statement and the supporting control framework at least annually, and sooner where there is a material change in law, guidance, risk exposure or business activity. Findings from risk assessments, incidents, investigations, audits and assurance activity will be used to improve our procedures.

Accountability at All Levels

Everyone covered by this statement is responsible for acting honestly, completing required training, following controls and raising concerns. Leaders are accountable for ensuring that risks within their areas are understood and managed. Failure to meet these standards may result in disciplinary action, legal proceedings or removal from our supplier or partner network.