This policy provides guidance on our responsibilities in relation to all elements of anti-bribery and corruption. We conduct our business in an honest and ethical manner. We won’t tolerate any acts of bribery and corruption and are committed to: acting professionally and ethically in all our business dealings and relationships, wherever we operate implementing and enforcing effective systems to counter bribery. The Bribery Act 2010 contains two general offences covering the offering, promising or giving of a bribe (“active” bribery) and the requesting, agreeing to receive or accepting of a bribe (“passive” bribery). The Act also introduces a new form of corporate liability for failing to prevent bribery on behalf of a commercial organisation. An individual found to have committed an offence of bribery can be imprisoned for a term of up to ten years, and as a business we could face an unlimited fine for any bribery related offences committed by someone associated with us. We take our responsibilities in relation to this very seriously and all colleagues are required to comply with our procedures to prevent any acts of bribery and corruption. Gifts and hospitality Subject to prior authorisation by agreed approvers, we allow reasonable and proportionate hospitality and promotional or other similar business expenditure intended for these purposes. However, we’re conscious offers or receipts of hospitality and other similar business expenditure can be employed as a form of bribery – so all corporate gifts and receipts of this nature are reported and duly authorised. The giving or receipt of gifts is permitted, if the following requirements are met: it’s not made with the intention of influencing a third party to obtain or retain business / a business advantage, or to reward the provision or retention of business / a business advantage, or in explicit or implicit exchange for favours or benefits it complies with the law it’s given in our business name, not in the name of individuals it doesn’t include cash or a cash equivalent (such as gift certificates or vouchers) it’s appropriate in the circumstances, for example, it’s often customary for small gifts to be given at Christmas time taking into account the reason for the gift, it’s of an appropriate type and value and given at an appropriate time it’s given openly, not secretly it’s not offered to, or accepted from, government officials or representatives or politicians or political parties, without prior approval. In all circumstances, the test to be applied is whether the gift or hospitality is reasonable and justifiable. We deem it unacceptable for our colleagues (or someone on their behalf) to: 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 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 accept payment from a third party that you know, or suspect is offered with the expectation that it’ll obtain a business advantage for them accept a gift or hospitality from a third party if you know or suspect that it’s offered or provided with an expectation that a business advantage will be provided by us in return threaten or retaliate against a colleague who has refused to commit a bribery offence or who has raised concerns in relation to these standards or engage in any activity that might lead to a breach of these standards. Facilitation payments We don’t make, and won’t accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. Kickbacks are typically payments made in return for a business favour or advantage. All colleagues will avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us. 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 parties are required to avoid any activity that might lead to, or suggest, a breach of these standards. Confidential and safe reporting procedures We’re aware thar workers who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith. We’re committed to ensuring that no one suffers any detrimental treatment as a result of raising any concerns under this policy. Training and implementation Training on this policy forms part of the induction process for all new workers. All existing workers also receive regular, relevant training on how to implement and adhere to it. Our zero-tolerance approach to bribery and corruption is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter. Our CEO has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The relevant Director has primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
