Anticorruption, Bribery and Whistleblowing

Introduction

It is the company’s policy to conduct its business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

The company is bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct. Bribery is a criminal offence. The Company prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero tolerance attitude towards corrupt activities of any kind, whether committed by employees or by third parties acting for or on behalf of the Company.

Policy

It is prohibited, directly or indirectly, for any employee or person working on our behalf to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or Company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

Definitions

Corruption is the abuse of public or private office for personal gain. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage through “improper performance” by the bribe recipient.
Improper performance happens when a person fails to act (1) in good faith, (2) impartially or (3) in accordance with a position of trust (i.e. abuse of office).

This policy defines Bribery as occurring when one person offers, pays, seeks or accepts a payment, gift, favour, or other advantage from another to influence a business process and outcome improperly, or to induce or reward improper conduct.

Bribery and corruption – whether involving government officials or commercial entities, can be direct or indirect through third parties such as agents, brokers, consultants and joint venture partners. It includes facilitation payments even though in some countries these are legal.

Suspicion

If you suspect that we have committed an act of bribery or attempted bribery, an investigation will be carried out in line with our procedures and inline with The Bribery Act, 2010.

Reporting

If you, as an external stakeholder suspect that an act of bribery or attempted bribery has taken place, even if you are not personally involved, you can find more information on the correct route to report here: https://protect-advice.org.uk/#support-for-individuals. For Information Security data breaches, you can find more information on whistleblowing here: https://ico.org.uk/make-a-complaint/protection-for-whistleblowers-guidance/.

Gifts And Hospitality

We realise that the giving and receiving of gifts and hospitality as a reflection of friendship or appreciation where nothing is expected in return may occur, or even be commonplace, in our industry. This does not constitute bribery where it is proportionate and recorded properly.

No gift should be given nor hospitality offered by any of our employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval.

Similarly, no gift or offer of hospitality should be accepted by our employees or anyone working on our behalf without receiving prior written approval.

Record Keeping

A record will be made by CFMS of every instance in which gifts or hospitality are given or received.

This policy is subject to review and the Company reserves the right to amend this policy without prior notice.