Anti-Corruption & Bribery Policy

It is our policy to conduct all of our business in an honest and ethical manner. We
are committed to acting professionally, fairly and with integrity in all our business
dealings and relationships wherever we operate and implementing and enforcing
effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption. However, we
remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

The purpose of this policy is to:

I. set out our responsibilities, and of those working for us, in observing and
upholding our position on bribery and corruption; and
II. provide information and guidance to those working for us on how to
recognise and deal with bribery and corruption issues.

 
This policy is non-contractual in its effect and does not form part of normal terms and conditions of employment, unless otherwise stated in your contract of employment. It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years' imprisonment and/or a fine. As an employer if we fail to prevent bribery, we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously.

In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

1. Who must Comply with this Policy?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located (collectively referred to as workers in this policy).

2. What are Bribery and Corruption?

Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.

A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust.

The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.

Corruption is the abuse of entrusted power or position for private gain.

3. What you Must not do

It is not acceptable for you (or someone on your behalf) to:

a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

b) give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;

c) accept hospitality from a third party that is unduly lavish or extravagant under the circumstances.

d) accept a payment, gift or hospitality from a third party that you know, or suspect is offered with the expectation that it we will provide a business advantage for them or anyone else in return;

e) offer or accept a gift to or from government officials or representatives, or politicians or political parties, without the prior approval of your Line Manager;

f) threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

g) engage in any activity that might lead to a breach of this policy.

4. What is not Acceptable?

It is not acceptable for you (or someone on your behalf) to:

a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

b) give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure;

c) accept payment from a third party that you know, or suspect is offered with the expectation that it will obtain a business advantage for them;

d) accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

e) threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

f) engage in any activity that might lead to a breach of this policy.

5. Facilitation Payments and Kickbacks

We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments, also known as "back-handers" are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in the UK but are common in some other jurisdictions.

Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with your Line Manager.

6. Gifts, Hospitality and Expenses

This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:

I. establishing or maintaining good business relationships;

II. improving or maintaining our image or reputation; or

III. marketing or presenting our products and/or services effectively.

The giving and accepting of gifts is allowed if the following requirements are met:

I. it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

II. it is given in the Company name, not in your name;

III. it does not include cash or a cash equivalent (such as gift certificates or vouchers);

IV. it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas; and

V. it is given openly, not secretly;

VI. it complies with any applicable local law.

Promotional gifts of low value such as branded stationery to or from existing customers, suppliers and business partners will usually be acceptable. Reimbursing a third party's expenses or accepting an offer to reimburse our expenses, (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable. We appreciate that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. The intention behind it should always be considered. 

7. Potential Risk Scenarios: "red flags"

The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anticorruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.

If you encounter any of these red flags while working for us, you must report them promptly to your Line Manager using the procedure set out in the whistleblowing policy:

I. you become aware that a third party engages in, or has been accused of engaging in, improper business practices;

II. you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials;

III. a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;

IV. a third-party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

V. a third-party request that payment is made to a country or geographic location different from where the third party resides or conducts business;

VI. a third party requests an unexpected additional fee or commission to "facilitate" a service;

VII. a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;

VIII. a third-party request that a payment is made to "overlook" potential legal violations;

IX. a third-party request that you provide employment or some other advantage to a friend or relative;

X. you receive an invoice from a third party that appears to be non-standard or customised;

XI. a third party insists on the use of side letters or refuses to put terms agreed in writing;

XII. you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;

XIII. a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;

XIV. you are offered an unusually generous gift or offered lavish hospitality by a third party. 

8. Your Responsibilities

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your Line Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us or indicates to you that a gift or payment is required to secure their business. Any employee who breaches this policy could face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with agency or other workers if they breach this policy.