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1 About this policy
1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
1.2 It is important that you understand that any member of staff found to have breached this policy will face disciplinary action, which could result in dismissal for gross misconduct.
2 What is bribery?
2.1 Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
2.2 Bribery includes offering, promising, giving, accepting or seeking a bribe.
2.3 All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, always raise it with your line manager or a senior colleague if in doubt.
2.4 Specifically, you must not:
a. give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
b. accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
c. give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.
2.5 You must not threaten or retaliate against another person who has refused
3 Gifts and Hospitality
3.1 This policy does not prohibit giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
3.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
3.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.
3.4 Nobody is allowed to accept gifts, services or other benefits or perks from customers, suppliers or other third parties at any time which exceed a value of £100 without disclosing this at the time to either their line manager, a senior colleague or a member of the Human Resources Department. However, at certain times of the year e.g. Christmas, it is acknowledged that gifts may be offered more frequently and refusal may be perceived negatively by the person offering the gift. At this time of year, all gifts must be collected and logged centrally with a member of the Human Resources Department so that the appropriate arrangements can be made. Gifts will then be pooled and shared fairly and equally between all colleagues employed at the time. Only if a gift is expressly given to you as an individual does it fall outside of this policy but for the avoidance of doubt, we encourage all such personal gifts to be disclosed to a member of the Human Resources Department. Any person seen or known to be soliciting such gifts (whether actually or implicitly) or in breach of the above policy may be subject to our disciplinary procedure.
4 Record Keeping
4.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
4.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
5 How to raise a concern
5.1If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you are expected to report this without delay to our Financial Controller or report it in accordance with our whistleblowing policy as soon as possible.