Anti-bribery & Corruption Policy

What is Bribery?

Bribery is the accepting or giving of gifts, money, hospitality or other favours in return for providing something of value to the briber.

This is defined as giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person from having already done so i.e. seeking to influence a decision-maker by giving extra benefit to that decision-maker rather than by what can be legitimately offered as part of the tender process.

Who does this Policy cover?

The policy applies to all employees and agents alike.

What is the purpose of this Policy?

The purpose of this policy is to set out the rules that must be followed throughout the Company to ensure that no bribery or corruption occurs.

Scope

To comply with the legislation, we need to:

Have adequate procedures in place to prevent bribery

Have conducted a risk assessment to ensure that procedures are adequate to minimise the risk

That any action taken is proportionate to the risk within the Company

Top level commitment – demonstrate that all staff, agents and the key people with whom we do business with & for understand that we will not tolerate bribery

Due diligence – know exactly whom we are dealing with and undertake checks before engaging others to represent us in business dealings.

Communicate policies & procedures to all employees and agents to enhance awareness and advise what is acceptable

Monitoring & review – keep track of the risks faced particularly if entering a new market

Unacceptable behaviour

Accepting any financial or other reward from any person in return for providing some favour

Requesting a financial or other reward from any person in return for providing some favour

Offering any financial or other reward from any person in return for providing some favour

Business Gifts

From time to time, customers, suppliers or other persons might offer a gift or reward to an employee. This could be anything from a small gift, money or something else of considerable value.

All gifts, however small, must be reported to an appropriate manager and recorded. No gifts with a value of more than £10 may be accepted.

If a gift is offered and then refused because of its value, this must be reported to an appropriate manager.

Hospitality

From time to time customers, suppliers or other persons may invite an employee to a hospitality event such as a meal, football match, business party, horse-racing or wine-tasting.

All such invitations must be reported to an appropriate manager for authorisation prior to accepting the offer to attend the event.

Offering gifts & hospitality

The company may consider that from time to time, it is reasonable to offer small gifts or rewards to customers, suppliers or other persons. This may only be done when authorised by an appropriate manager together with the company chief executive.

Only when authorised by the company chief executive will any employee or agent be allowed to offer gifts or rewards to customers, suppliers and other persons. In any such event a full record will be kept, providing details of the gifts/rewards and recipients by the company.

The company may occasionally hold hospitality events, primarily aimed at thanking customers, suppliers and other persons for their custom, loyalty, effectiveness or achievements. An employee must not organise any additional hospitality event without seeking authorisation from appropriate manager in conjunction with the chief executive.

Responsibilities of Staff

All members of staff are responsible for reporting to the Compliance Officer all gifts & hospitality that is/are offered and/or received.

The Compliance Officer is responsible for ensuring that all their responsible employees and agents are aware of this policy and fully understand the rules in relation to the acceptance of gifts & hospitality.

Expenses

The Compliance Officer must authorise all expenses claims from their employees and are expected to verify spending in this area by matching receipts.

Any item of expenditure that is not supported by a receipt or gives rise to concern that bribery may be taken place must be fully investigated at the earliest opportunity.

Attempts to bribe

Any employee or agent who is concerned that he/she is potentially being bribed should report this matter to the Compliance Officer immediately.

Donations to organisations

From time to time, the company may make a charitable donation. These are managed by the firm’s Principal/ Managing Director.  No employee should make donations to charity on behalf of the Company unless authorised by firm’s Principal/ Managing Director.

Under no circumstances are donations to be made to charities, political parties or other organisations with the intention of gaining personal or business advantage.

Raising concerns

If an employee or agent is concerned that acts of bribery are occurring within the organisation they should inform the Compliance Officer immediately.

If an employee or agent is concerned that a supplier or company that we do business with may be corrupt, this should also be reported to the Compliance Officer immediately.

Disciplinary action

All allegations of bribes being offered and/or received by an employee will be thoroughly investigated and dealt with using the company’s disciplinary procedure.

The company will deem proven cases as Gross Misconduct and consequently disciplinary action, including summary dismissal could be considered.

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