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 we are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and in implementing and enforcing effective systems to counter bribery.
1.2 We will uphold all laws relevant to countering bribery and corruption. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.
1.3 The purpose of this policy is to:
(a) set out our responsibilities and of those working for us, in observing and upholding our position on bribery and corruption; and
(b) to provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.
1.4 Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and if we are found to have taken part in corruption we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously and we have conducted a risk assessment to identify any key areas which may potentially pose a particular risk to our organisation.
1.5 In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
Offering a bribe
You offer a potential research client tickets to a major sporting event, but only if they agree to do business with us.
Receiving a bribe
A supplier gives your nephew a job, but makes it clear that in return they expect you to use your influence in our organisation to ensure we continue to do business with them.
Bribing a foreign official
You arrange for the company to pay an additional payment to a foreign official to speed up an administrative process.
4.1 This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties.
4.2 The giving or receipt of gifts is not prohibited, if the following requirements are met:
4.3 We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
6.1 We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. They are not commonly paid in the UK, but are common in some other jurisdictions.
6.2 If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Managing Director.
6.3 Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
8.1 You must ensure that you read, understand and comply with this policy.
8.2 The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
8.3 Any employee who breaches this policy will face disciplinary action, which may result in dismissal. We reserve our right to terminate our contractual relationship with other workers and organisations if they breach this policy.
9.1 We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
9.2 You must declare and keep a written record of all hospitality or gifts accepted or offered in accordance with the company’s Financial Regulations and Expenses and Benefits Procedures, you must also ensure that all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with such regulations.
10.1 You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with the Managing Director. You should raise a concern as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further “red flags” that may indicate bribery or corruption are set out in the Appendix.
10.2 Concerns should be reported as a protected disclosure to your line manager or the Managing Director. Statutory protection of whistleblowers is afforded under the Public Interest Disclosure Act 1998.
11.1 Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws.
The list is not intended to be exhaustive and is for illustrative purposes only.
If you encounter any of these red flags while working for us, you must report them promptly to the Managing Director: