We are committed to the prevention, deterrence, and detection of bribery. We have zero tolerance towards bribery and a strict anti-bribery and anti-corruption policy in accordance with the Bribery Act 2010.
Objective of this policy
This policy provides a consistent framework to enable the company’s employees to understand and enable compliance. It will also enable employees to identify and effectively report a potential breach.
We require that all personnel, including those permanently employed, temporary agency staff and contractors:
• act honestly and with integrity at all times.
• comply with the laws and regulations of all jurisdictions in which the company operates.
Scope of this policy
This policy applies to all business activities.
The responsibility to control the risk of bribery and corruption occurring resides at all levels of the company and covers all personnel, including all levels and grades, those permanently
employed, temporary agency staff, contractors, subcontractors, volunteers and consultants.
Bribery
Is an inducement or reward offered, promised or provided to gain personal, commercial,
regulatory or contractual advantage.
Corruption
Corruption is a form of dishonesty or a criminal offense which is undertaken by a person or an organization which is entrusted in a position of authority, in order to acquire illicit benefits or abuse power for one’s personal gain.
Compliance
It is prohibited to:
1. Either give, promise or receive an offer of payment, gift or hospitality with the expectation or hope to gain a business or personal advantage, or reward an advantage already given.
2. Either give, promise or receive an offer of payment, gift or hospitality to facilitate or expedite a routine procedure.
3. 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.
4. Retaliate against or threaten a person who has refused to commit an offence or who has raised concerns under this policy.
Such an act of bribery and/or corruption would include (but are not limited to):
1. “Facilitating Payments”: unofficial payments to public officials in order to secure or expedite actions.
2. Receiving a “kickback” (gift or payment) in return for your influence to obtain a contract.
3. Any offer of payment, gift, hospitality or benefit in return for the release of data.
4. Any offer of advantage, personal or commercial, to a customer in order to secure or procure new business for the company.
5. Any act of embezzlement, theft and fraud.
6. The political act of Graft: any involvement in the intentional misdirection of funds intended for public projects for personal benefit.
7. Any act that amounts to extortion and blackmail.
8. Influence Peddling: the illegal practice of using influence with persons in authority to gain favours or preferential treatment.
Failure to comply with this Policy will result in disciplinary action in line with the Discipline Policy and where appropriate criminal investigations will be conducted.
Responsibilities
The prevention, detection and reporting of bribery and other forms of corruption are the
responsibility of all those working for the company or under its control. All staff are required to avoid activity that breaches this policy.
The employees must:
1. Ensure that you have read, understood and comply with this policy.
2. Immediately disclose to a Company Director if you believe or suspect that such a bribe has been given or received by an employee. Failing to report such matter may result in the employee being dismissed for gross misconduct.
3. Immediately disclose any gift or benefit in kind received to a Company Director.
The Company Directors must:
1. Train all staff to ensure that they have understood this policy.
2. Monitor the effectiveness and implementation of this policy.
3. Vigorously investigate all suspicions and allegations in breach of this policy.
4. Identifying the risks to which company activities may be vulnerable to breaches of this policy and ensure adequate controls are in place to prevent it.
5. Take the appropriate legal and disciplinary action against perpetrators and staff who fail to report concerns where this is proven.
The Company reserves its rights generally, and the Employee accepts that he may be held liable for the losses suffered by the Company as a result of his actions in breach of this policy.
Any employee found in breach of this policy, in the reasonable belief of the Company’s Directors, may be dismissed for gross misconduct as well as the possibility of civil and criminal prosecution.
20th January 2025
