Policy
Anti-Bribery and Corruption Policy
"We are committed to preventing bribery, corruption, fraud, and other unethical practices in all its business dealings."
Scope
This policy applies to:
- All employees, directors, and officers
- Contractors, consultants, agents, and intermediaries acting on behalf of the organisation
- Subsidiaries, joint ventures, and business partners over which the organisation has control
It covers all business activities, including dealings with government bodies, clients, suppliers, and charitable organisations.
Commercial Bribery
"Employees and representatives must not offer, promise, give, request, or accept any bribe or improper advantage to gain or retain business."
Commercial bribery includes:
- Kickbacks, secret commissions, or other inducements
- Payments or gifts intended to secure an improper business advantage
Falsification of Company Books and Records
"All financial and non-financial records must be accurate, complete, and transparent."
Employees must not:
- Make false entries in accounts or records
- Conceal transactions or misstate liabilities, revenues, or assets
- Create off-the-books accounts or undisclosed funds
"Any suspicious activity must be reported immediately to management or via the whistleblowing mechanism."
Dealing with Government Intermediaries
Interactions with government officials or intermediaries must:
- Be fully transparent and documented
- Avoid improper influence or inducement
- Comply with all relevant anti-bribery, lobbying, and procurement laws
"Payments to government intermediaries must be pre-approved and properly recorded."
Charitable Contributions
Charitable donations or sponsorships must:
- Be genuine and for legitimate purposes
- Not be used as a disguise for bribery
- Be approved in advance by management
- Be fully documented in the company's accounts
Money Laundering
"The organisation will not participate in or facilitate money laundering."
Employees must:
- Verify the identity of clients, suppliers, and business partners where required
- Report suspicious transactions to management or the Money Laundering Reporting Officer
- Ensure all payments are lawful and traceable
Gifts and Entertainment
Gifts, hospitality, or entertainment must be:
- Reasonable, proportionate, and transparent
- Approved according to company thresholds
- "Never intended to secure an improper advantage"
"Employees must decline or report gifts that could influence, or appear to influence, business decisions."
Conflicts of Interest
"Employees must avoid situations where personal interests conflict with company interests."
This includes:
- Financial or personal relationships with clients, suppliers, or competitors
- Accepting gifts or benefits that could influence judgement
- Undertaking outside activities that compete with or damage the organisation
"Conflicts must be declared to line management."
Whistleblowing / Grievance Mechanism
Employees are encouraged to report:
- Suspected bribery, corruption, or fraud
- Breaches of this policy
- Any other unethical or illegal conduct
"Reports can be made confidentially and without fear of retaliation, via the company's managing director."
Facilitation Payments
"The organisation prohibits facilitation or 'grease' payments, regardless of local customs."
"No employee or representative should make payments to secure or expedite routine government actions."
Relationships with Third Parties
All third parties acting on behalf of the organisation must:
- Comply with this policy
- Be vetted for integrity and risk before engagement
- Be bound contractually to anti-bribery and anti-corruption obligations
"Managers must ensure ongoing monitoring of third-party compliance."
Cartels or Market Rigging
"Employees must not engage in anti-competitive behaviour, including:"
- Price-fixing or market-sharing agreements
- Bid-rigging or collusion with competitors
- Any activity that breaches competition law
"Any suspected cartel activity must be reported immediately."
Independent Investigation or Adjudication
All reports of bribery, corruption, or policy breaches will be:
- Investigated promptly, independently, and confidentially
- Documented with evidence
- Escalated to management, legal, or external investigators as required
"Corrective and disciplinary actions will be taken, up to and including termination or legal prosecution."
Training and Awareness
The organisation will provide:
- Regular training for employees on anti-bribery, corruption, and related compliance topics
- Guidance for managers on risk identification and mitigation
- Updates on legislative changes and industry best practices
Consequences of Breach
Non-compliance may result in:
- Disciplinary action, including dismissal
- Termination of contracts with third parties
- Civil or criminal prosecution under UK law
Review
"This policy will be reviewed at least annually or following significant legislative, operational, or organisational changes."