Anti Bribery Policy

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 we suspect that you have committed an act of bribery or attempted bribery, an investigation will be carried out and, in line with our disciplinary procedure where appropriate, action may be taken against you which may result in your dismissal, or the cessation of our business arrangement with you.

Reporting

If you, as an employee or person working on our behalf, suspect that an act of bribery or attempted bribery has taken place, even if you are not personally involved, you are expected to report this to a Senior Manager.  You may be asked to give a written account of events.

Staff are reminded of the Company’s Whistleblowing Policy which is available in this Employee Handbook.

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 an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from your Line Manager.

Similarly, no gift or offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from your Line Manager.

Record Keeping

A record will be made by your Line Manager 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.

Talk to us today