Anti Bribery and Corruption Policy
We are committed to the highest ethical standards enforcing the integrity of our business practices, wherever we operate and complying with all anti-bribery and anti-corruption laws. We have
a zero-tolerance approach to bribery and corruption. These statements have been endorsed by the
Director and will be vigorously enforced. All employees are expected to comply with this policy in full.
Adherence to the guidelines set out in this policy will ensure that the company and its employees
comply with relevant laws, governmental guidance and recognised best practice. This in turn will
reduce the risk that the company or any employee will incur any criminal liability or reputational
The company does not take part in acts of corruption, or pay bribes or receive kickbacks either directly or indirectly.
The company prohibits its employees from engaging in acts of corruption, and from paying bribes or kickbacks to, or accepting bribes or kickbacks from, public officials and private individuals such as the personnel of companies with which the company does business.
It is the responsibility of all employees who are involved at any time in engaging the services of suppliers to ensure that such organisations or individuals are made aware of the content of the company’s Anti-Bribery and Anti-Corruption policy at the outset of the relationship and on a regular basis thereafter.
The company and its employees will not make facilitation payments even if such payments are local practice or custom.
If company employees encounter a demand for a facilitation payment, or think they are likely to do so, they should report the situation to the Director without delay.
The company recognises that demands for facilitation payments are often backed by a form of extortion. Staff must report any incident where they feel forced to make a facilitation payment to the Director at the earliest opportunity.
Bribing or corrupting a public official is a serious offence which can carry severe penalties and can cause significant reputational damage. The company will not offer any financial incentives or gifts to influence public officials in awarding contracts. Proposals will always be out writing and be transparent regarding the products and services we offer.
Company employees may not offer to, or accept from, third parties, gifts, hospitality, rewards, benefits or other incentives that could affect either party’s impartiality, influence a business decision or lead to the improper performance of an official duty. Similarly, they may not offer or accept cash donations.
Company employees may not offer or accept gifts and entertainment however small or insignificant. Such gifts compromise the companies impartiality and integrity and anyone falling foul of the guidelines will be disciplines and or dismissed from the company.
Company employees must avoid situations or transactions in which their personal interests could conflict or might be seen to be in conflict with the interests of the company. This includes: acting on any client information gained through their employment with the company for personal gain; passing such information to a third party; or acting in any way that could be construed as insider trading.
Conflicts of interest can arise if individuals have a personal interest in business dealings involving the company. Personal interest can be direct or indirect, and refers not only to personal interests but to those of family members and friends. If there is a potential for conflict, the interests of the company must take priority.
Employees must disclose any personal conflict of interest or perceived conflicts of interest to the Director
As part of its activities, the company may support charities or provide sponsorship, for example, to sporting or cultural events. Any such sponsorship will be approved by the Director and must be transparent and properly documented. The company will only provide donations to organisations that serve a legitimate public purpose, and which are themselves subject to high standards of transparency and accountability. Appropriate due diligence must be conducted on the proposed recipient charity and a full understanding obtained as to its bona fides.
The company has a policy of strict political neutrality; it does not make donations to any political parties, organisations, or individuals engaged in politics. The company will co-operate with governments and other official bodies in the development of policy and legislation that may affect its legitimate business interests, or where it has specialist expertise.
Employees are entitled to their own political views and activities, but they may not use company premises or equipment to promote those views or associate their views with those of the company.
The company expects its business partners to approach issues of bribery and corruption in a manner that is consistent with the principles set out in this policy. This requirement applies to agents, suppliers, sub-contractors, and joint venture partners. In cases where the company is unable to ensure these standards, it will reconsider the business relationship.
This policy applies with particular force to commercial agents, representatives and subcontractors. In many reported international corruption cases, agents have passed on part of their commissions as bribes. The company strictly prohibits such practices.
In order to maintain the highest standards of integrity, employees must ensure that:
They are fully briefed on the background and reputation for integrity of agents, representatives and subcontractors before hiring them. The company will conduct due diligence enquiries to review the integrity records of agents, representatives and subcontractors before entering a commercial relationship with them.
The engagement process is fully documented; and that final approval of the selection of agents, representatives and subcontractors is made by someone other than the person selecting or managing the company’s relationship with them.
Agents, representatives and subcontractors are fully briefed on the company’s Anti-Bribery and Anti- Corruption policy, and have made a formal commitment in writing to abide by it.
Fees and commissions agreed will be appropriate and justifiable remuneration for legitimate services rendered.
The need for documentation and careful reviews of the company’s partners’ integrity records applies equally to the process of setting up and managing joint ventures. The company will use its influence to ensure that joint ventures meet high integrity standards. Where the company has majority control, it will ensure that the joint venture adopts the concepts and approach to bribery and corruption as set out in this policy.
The company will ensure that the procurement procedure for appointing suppliers and contractors is open, fair and transparent. The selection of contractors will be based on an evaluation of professional merit, and not on personal recommendations.
The company will communicate its Anti-Bribery and Anti-Corruption policy to its suppliers and contractors, and it will expect them to abide by the principles set out in the policy when working on the company’s behalf. If those principles are breached, the company will reserve the right to terminate the contract.
We require employees to keep accurate accounts throughout the company’s operations. In no circumstances will the company be expected to keep parallel accounts.
We have documented procedures in place, which are regularly audited to ensure openness and compliance with all legal requirements.
All national laws relating to bribery and corruption, especially such laws that are in place in jurisdictions where the company carries out its work, are of importance. In setting out the principles included in this policy, particular attention has been paid to the requirements of:
The UK Bribery Act 2010 which has extra-territorial reach. The company is registered in the UK, and this law has particular relevance to the manner in which the company conducts itself;
The Managing Director has overall responsibility for the application of this policy.
The company will make this policy readily available on the company’s website and intranet for all interested parties. The policy will also form part of a new employee’s induction training programme.
The internal audit programme will audit compliance against this policy, and other company policies, at regular intervals. Compliance will also form part of regular legal reviews, by the company legal compliance advisor.
Employees should consult with the Director if they suspect that a company employee is engaged in bribery, corruption, fraud or any other unacceptable or unethical conduct.
Failure to ensure compliance with this policy could lead to the following consequences for the company:
Criminal or civil liabilities for the company including fines and imprisonment;
Serious reputational damage including media comment;
Exclusion from tendering for public sector contracts, and;
The unenforceability of contracts entered into as a result of acts of bribery, fraud or other illegality.
Failure to ensure compliance with this policy could lead to the following consequences for employees:
Personal criminal liability followed by fines or imprisonment;
Disciplinary action initiated by the company, including dismissal;
Personal reputational damage.
Employees in any case of uncertainty, or any cases of doubt, surrounding how to apply this policy, should speak with the Managing Director.
The policy will be reviewed annually, or earlier, should there be any significant changes, such as to governing legislation.