Anti-Bribery and Corruption Policy

2. Applicable Legislation

This policy is informed by and compliant with the following legislation:

The UK Bribery Act 2010. The Bribery Act creates offences of offering or receiving bribes, bribing foreign public officials, and failing to prevent bribery by associated persons. It applies to all UK companies and their associated persons regardless of where the conduct occurs. The Act covers commercial bribery between private companies as well as bribery involving public officials.

The US Foreign Corrupt Practices Act (FCPA). Many of our principals are US companies subject to the FCPA, which prohibits payments to foreign officials to obtain or retain business. As their European representative, we operate in a manner consistent with our principals' FCPA obligations.

EU anti-corruption legislation. We comply with applicable anti-corruption laws in every European country in which we operate, including the EU Anti-Corruption Directive and national implementing legislation across EU member states.

We also comply with all applicable sanctions, export control, and anti-money laundering regulations in the jurisdictions in which we operate.

3. What This Means in Practice

In our day-to-day work representing principals in the European aerospace and defence market, this policy means:

• We will never offer, promise, or give any payment, gift, or other advantage to any person in order to influence a procurement decision, secure a contract, or obtain any improper business advantage on behalf of ourselves or our principals.
• We will never request or accept any payment, gift, or other advantage in return for influencing a procurement decision or providing any improper business advantage.
• We do not make facilitation payments. We do not regard facilitation payments as acceptable in any jurisdiction.
• All gifts and hospitality given or received in the course of business must be modest, proportionate, transparent, and given in good faith. They must never be offered or accepted with the intention of influencing a business decision.
• We maintain accurate records of all business transactions, engagements, and expenses. We do not permit off-book accounts, secret funds, or undisclosed payments.
• We will cooperate fully with any due diligence process conducted by our principals or by the OEMs and Tier-1 suppliers we approach on their behalf.

4. Due Diligence and Transparency

We understand that our principals and the customers we engage with need confidence that their intermediaries operate to the highest standards. We welcome and actively support due diligence enquiries from:

• Principals evaluating Westworld as their European representative
• OEMs, Tier-1 suppliers, and defence primes whose compliance teams need to verify our credentials
• Trade associations, industry bodies, and regulatory authorities

We are transparent about our business model, our remuneration structure, and the nature of the services we provide. We do not operate through shell companies, undisclosed agents, or opaque corporate structures.

5. Responsibilities

All employees, directors, and contractors of Westworld Consulting Limited are required to:

• Read, understand, and comply with this policy
• Report any suspected breach of this policy or any concern about bribery or corruption, whether involving Westworld personnel, principals, customers, or any third party
• Cooperate with any investigation into a suspected breach
• Never engage in any activity that could give rise to a breach of this policy

The Board of Westworld Consulting Limited is responsible for maintaining this policy, ensuring compliance, and reviewing it at least annually.

6. Reporting Concerns

If you have any concerns about bribery or corruption relating to Westworld Consulting Limited, our activities, or any person acting on our behalf, you should report them to:

• Email: [email protected]
• Post: Compliance, Westworld Consulting Limited, 130 Aztec West, Bristol, BS32 4UB, United Kingdom
• Telephone: +44 (0) 1454 629 628

We take all reports seriously. Reports can be made in confidence. We will not tolerate retaliation against anyone who reports a genuine concern in good faith.

7. Review

This policy is reviewed annually by the Board of Westworld Consulting Limited and updated as required. The latest version is always available on this page.

Legal entity: Westworld Consulting Limited

Company registration: England and Wales, Company Number 08672769

Registered office: 130 Aztec West, Bristol, BS32 4UB, United Kingdom

Last reviewed: April 2026