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Anti-Bribery and Corruption Policy

Table of Contents

  1. Purpose 2
  2. Scope 2
  3. Anti-Bribery 2
  4. Related Policies 3
  5. Where to find further information 3
  6. Policy Owner 3
  7. Policy Review Date 3

1. Purpose 

We value our reputation for ethical behaviour, financial honesty, integrity and reliability. We have a number of fundamental principles and values which we believe are the foundation of sound and fair business practice and as such are important to uphold. The trust and respect of Company employees, clients, customers, stakeholders and the general public are assets that cannot be bought and are the foundation of our success. For these reasons our employees must conduct themselves in adherence with this policy. The impact of any wrongdoing or unethical behaviour upon our business could be both damaging and detrimental.

Every employee has a right to expect that our business maintains proper standards and everyone has a duty to maintain these standards through their decisions, actions and what they say. A heavier responsibility is borne by those who hold positions of authority. They must openly demonstrate leadership in applying the business practices outlined in this Policy.

This Policy is supported by the business and shall be reviewed from time to time. The policy covers the main issues that may be encountered at work and sets out standards of professionalism and integrity to be maintained by individuals.

All employees have the right and the responsibility to resolve doubts or uncertainties about ethical questions and should, in the first instance, contact their line manager for guidance prior to taking any action. An ‘open door’ policy is encouraged throughout our business so that, if necessary, such queries can be brought to the attention of higher levels of management. The Company also has a Whistleblowing Policy where specific concerns can be raised without fear of discrimination. 

  1. Scope 

This Policy applies to all employees, consultants, contractors or any other people or any other company associated with our business or any of our subsidiaries, associated companies, and their employees.

  1. Anti-Bribery 

It is Company policy to comply with all laws, rules and regulations governing anti bribery and corruption law. Under UK law, bribery and corruption is punishable for individuals by up to ten years imprisonment, and if the business is found to have failed to prevent bribery or taken part in corruption it could face an unlimited fine, be excluded from tendering for Government contracts and face untold damage to its reputation.

Under UK law the payment, or offer to pay bribes, or the provision of or offer to provide gifts or anything of value or other advantage for improper purposes to obtain or retain business or any other benefit, (whether for the Company or any other party) is prohibited. Such payments or gifts are also forbidden under the terms of this Policy and may result in immediate dismissal for those involved in their payment or receipt.

The Company, nor any of its employees, will offer, give or receive bribes or inducements of any sort for any purpose. A bribe includes any payment, benefit, or gift offered or given with the purpose of influencing a decision or outcome. The payment may not be of large value, and it could be as simple as a lunch or for example, an invitation to a sporting event. We are each responsible for knowing what our business guidance allows and what the law permits regarding gifts and benefits given to or received from clients, customers, suppliers or other third parties. Always seek guidance and approval from your line manager before accepting or giving any gift or entertainment.

The business recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Our aim therefore is to limit any exposure to bribery by:

• Setting out a clear anti-bribery stance

• Training all employees so that they can recognise and avoid the use of bribery by themselves and others

• Encouraging employees to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately

• Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution

• Taking firm and vigorous action against any individual(s) involved in bribery.

In addition, we will keep financial records and to have appropriate internal controls in place which will evidence the business reason for making payments to third parties. 

  1. Related Policies

• Business Gifts Policy

• Business Expenses Policy

• Code of Conduct Policy

• Disciplinary Policy

• Whistleblowing Policy 

The above list is not exhaustive and other Company policies may be applicable

  1. Where to find further information 

If you require further information on this policy or procedure, then please speak with your Line Manager in the first instance. 

  1. Policy Owner 

This policy is owned and maintained by the QMS owner. 

  1. Policy Review Date 

Date Last reviewed: March 2022

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