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Anti-bribery and Anti-corruption

This policy outlines our anti-bribery and anti-corruption procedures.

We are committed to conducting our business with integrity, transparency, and fairness. As part of this commitment, we have implemented an Anti-Bribery and Anti-Corruption Policy to ensure that all employees, contractors, and third parties acting on our behalf comply with applicable laws and ethical standards.

Bribery and corruption are serious offences that can have severe legal and reputational consequences for both the individual and the company. This policy outlines the behaviours expected of you and the procedures in place to prevent bribery and corruption within our organisation.

Prohibited conduct

Bribery involves offering, promising, giving, receiving, or soliciting something of value as a way of influencing the actions of an individual in a position of trust or authority. Corruption refers to the abuse of power for personal gain. Both are strictly prohibited.

Examples of prohibited conduct include, but are not limited to:

  • Offering or accepting any form of bribe, whether cash or non-cash, in connection with your employment.
  • Making facilitation payments, which are unofficial payments made to expedite a routine government action.
  • Offering or accepting excessive gifts or hospitality that could be perceived as influencing business decisions.
  • Making donations to political parties or charities with the intention of securing a business advantage.

You must not engage in any activity that could be perceived as bribery or corruption. This applies to all aspects of your work, including interactions with clients, suppliers, government officials, and other third parties.

Gifts and hospitality

Gifts and hospitality can be part of building and maintaining good business relationships. However, they must be reasonable, proportionate, and not intended to influence the outcome of a business transaction.

You are allowed to offer or accept gifts and hospitality within the following guidelines:

  • Gifts should be of modest value and given as a gesture of goodwill, not as a means to influence a business decision.
  • Hospitality, such as meals or entertainment, should be reasonable in value and in line with normal business practices.
  • All gifts and hospitality must be declared and approved by your Manager.

If you are unsure whether a gift or hospitality is appropriate, you should seek advice from your Manager before proceeding.

Reporting suspicions

If you suspect that bribery or corruption is taking place within the company or in connection with the company’s business, you have a duty to report it immediately. Reports can be made confidentially to your Manager, HR, or through the company’s whistleblowing procedure.

The company is committed to investigating all reports of bribery and corruption thoroughly and confidentially. We will take appropriate action against anyone found to be involved in such activities, which may include disciplinary action, dismissal, and reporting the matter to the relevant authorities.

Record-keeping

Accurate and complete record-keeping is essential for preventing bribery and corruption. You are required to maintain records of all business transactions, including any gifts, hospitality, or other benefits received or given.

These records must be kept in accordance with the company’s policies and procedures and be available for inspection if required. Falsifying records or failing to keep proper records may result in disciplinary action and could lead to criminal prosecution.

Training and communication

To ensure that all employees understand the Anti-Bribery and Anti-Corruption Policy, the company provides regular training and updates. It is your responsibility to attend any training sessions provided and to familiarise yourself with the contents of this policy.

This policy will be communicated to all employees, contractors, and third parties working with the company. Managers are responsible for ensuring that their teams understand and comply with the policy.

Consequences of non-compliance

Failure to comply with the Anti-Bribery and Anti-Corruption Policy can have serious consequences for both the individual and the company. This includes legal action, financial penalties, and damage to the company’s reputation.

Employees who breach this policy will face disciplinary action, which may include dismissal. In addition, the company will not hesitate to report any unlawful activities to the relevant authorities.

It is crucial that all employees understand the importance of this policy and adhere to it in all aspects of their work.

 

This policy will be reviewed annually or as necessary to ensure it remains relevant and effective. The organisation reserves the right to amend this policy at any time, subject to consultation with employees and their representatives where appropriate.