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Anti-Bribery & Corruption Policy

The Bribery Act 2010 came into force in the UK on 1 July 2011, and not only makes bribery and corruption illegal, but also holds UK companies liable for failing to implement adequate procedures to prevent such acts by those working for the company or on its behalf, no matter where in the world the act takes place.

Equivo structure and business

Equivo was launched on 1 June 2021 as an innovative full-service recoveries business that delivers tech-enabled services to the highest standards across all stages of the debt and recoveries lifecycle.

Equivo is a trading name of Equivo Limited.

Equivo Limited is a limited liability company registered in England and Wales number 12058753. Equivo Limited’s registered office is Abbots House, Abbey Street, Reading, RG1 3BD. The addresses and contact information for each of our trading addresses can be found under the "Contact us" section of our website.

Equivo Limited is authorised and regulated by the Financial Conduct Authority (FCA). Firm Reference Number is FRN 845356. Details can be found on the Financial Services Register at We offer consumer credit and mortgage debt recoveries services.

Equivo Limited is also authorised and regulated by the Solicitors Regulation Authority (SRA), our SRA number is 811299. Our professional rules can be accessed, in English, from the Solicitors Regulation Authority website at

Equivo Limited has three key divisions; Collections & Field, Legal Services and Enforcement covering all disciplines within the recoveries lifecycle. Equivo Limited is authorised and regulated by the Financial Conduct Authority, the Solicitors Regulation Authority and authorised by the Ministry of Justice, coming together to enable unique in-house capabilities and expertise at national scale across four regional offices and supported by a nationwide field team.

Business support teams include, Finance, HR, Estates management, Information Technology, Compliance and Risk.


  1. Equivo is committed to operating responsibly wherever and whoever we work with in the world. We take pride in being an ethical transparent company which acts with integrity at all times.
  2. Equivo has a zero-tolerance policy to bribery and corruption. We will never offer, promise, pay, make, seek or accept either directly or through a third party, a bribe to obtain new business, retain existing business or secure any business advantage.
  3. We require all employees and associated persons to comply fully with all applicable anti-bribery legislation including the UK Bribery Act 2010 (“the Act”) and professional regulations applicable to our activities.
  4. In the eyes of the law, bribery and corrupt behaviour can be committed by: an employee, Appointed Representative or director; any person acting on behalf of Equivo; individuals and organisations where they authorise someone else to carry out these acts.
  5. Equivo prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether this be cash or otherwise;
    • to or from any person or company, whether a public official or public body, a private person or company wherever situated;
    • by any individual employee, agent or other associated person or company acting on Equivo’s behalf;
    • in the form of a gift or entertainment provided to the decision maker’s spouse or other members of their family;
    • in order to gain any commercial, contractual or regulatory advantage for Equivo in a way that is unethical; or
    • in order to gain any personal advantage, monetary or otherwise, for the individual or anyone connected with the individual.
  1. Facilitation payments will not be accepted, even where it is a recognised way of doing business in some countries.
  2. Equivo will not make any direct or indirect contributions to any political parties.

Employee responsibilities

All employees must;

  • act with integrity and carry out our business in a fair, honest and open way;
  • comply with Equivo’s Anti-Bribery and Corruption policy (ABC);
  • apply appropriate due diligence procedures in the selection of suppliers, business partners or agents to reduce any bribery risk and take steps to ensure the suppliers etc are aware of the requirements of the Act and have appropriate compliant policies;
  • report any instance to Compliance Department where they are offered a financial or other advantage which may constitute a bribe or where they think they have been offered or provided hospitality or a gift outside what they consider to be normal;
  • report any instances to Compliance Department where they are aware that a colleague has received a financial or other advantage that has not been reported as required under this policy;
  • decline to do business with others who do not accept our principles and who may harm our reputation;
  • not make use of their position in the company to further their private interests or those of others, including their family members;
  • abide by Equivo’s principles even when it becomes difficult.

Steps taken to prevent bribery or corruption

Equivo takes the following steps to assist in the prevention of bribery and corruption:

  1. Risk assessment

Effective risk assessment lies at the very core of the success or failure of ABC. Risk identification pinpoints the specific areas in which we face bribery and corruption risks and allows us to better evaluate and mitigate these risks and thereby protect ourselves.

  1. Accurate accounting and record-keeping

Many serious bribery and corruption offences have been found to involve some degree of inaccurate record-keeping. We must ensure that we maintain accurate books, records and financial reporting within Equivo. Our accounts, records and overall financial reporting must also be transparent. False, misleading and inaccurate records of any kind could potentially damage Equivo.

  1. Effective monitoring and internal control

We must maintain an effective system of internal control and monitoring of transactions. Once bribery and corruption risks have been identified and highlighted via the risk assessment process, procedures can be developed within a comprehensive control and monitoring programme in order to help mitigate these risks on an ongoing basis.


Bribery: the offering, promising, giving, accepting or soliciting of a financial or other advantage as an inducement for an action which is improper, illegal or a breach of trust.

Bribe: a financial or other advantage which is an inducement for an action which is improper, illegal or a breach of trust.

Associated persons: employees, suppliers, agents, individuals or organisations performing services on behalf of Equivo.

John Ingram
Equivo Limited

Date: 01 June 2021