1. Objective

The aim of this policy is to establish measures that ensure compliance with relevant anti-bribery and corruption regulations while promoting socially responsible business conduct within the Company.

 

2. Policy Declaration

Bribery encompasses actions such as offering, promising, giving, accepting, or requesting incentives that are illegal or breach trust.

A bribe refers to inducements or rewards provided to gain illegal or improper commercial, contractual, regulatory, or personal advantages. Our commitment is to conduct business honestly and ethically. We maintain a zero-tolerance stance towards bribery and corruption.

We pledge to act with fairness and integrity in all our business transactions and relationships, irrespective of our geographical presence. We will enforce robust systems to combat bribery and adhere to all relevant laws, including the UK's Bribery Act 2010, both domestically and internationally. Bribery and corruption can result in individuals facing up to ten years of imprisonment and fines. 

Engaging in corruption could lead to unlimited fines, exclusion from public contract bidding, and damage to our reputation. Thus, we take our legal responsibilities very seriously.

 

3. Coverage

3.1 Who Falls Under the Policy? In this policy, "third party" encompasses any individual or organisation encountered during your work for us, including actual or potential clients, customers, suppliers, distributors, business contacts, agents, advisers, government and public bodies, politicians, and political parties, along with their representatives and officials.

This policy applies to all individuals at every level and grade, including senior management, officers, directors, permanent, fixed-term, or temporary employees, consultants, contractors, trainees, seconded staff, remote workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any person associated with us, our subsidiaries, or their employees, regardless of location (referred to as employees in this policy). This policy addresses:

• Bribes; 

• Gifts and hospitality; 

• Facilitation payments; 

• Political contributions; 

• Charitable contributions.

 

3.2 Bribes Employees must refrain from engaging in bribery in any form, either directly or through a third party, such as an agent or distributor.

3.3 Gifts and Hospitality Employees must not offer or provide gifts or hospitality that could be considered illegal or improper or contravene the recipient's policies unless approved in writing by the managing director. Employees may not accept cash gifts or hospitality that implies the expectation of favours, unless approved in writing by the managing director. If declining a gift is inappropriate, it may be accepted, provided it is declared to the managing director and donated to charity.

3.4 Political Contributions We do not make donations, whether in cash or kind, to support any political parties or candidates, as this can be seen as an attempt to gain an improper business advantage.

3.5 Charitable Contributions We encourage and accept charitable support and donations in various forms. However, employees must ensure that charitable contributions are not used to conceal bribery. All charitable donations must comply with local laws and practices and be approved by the managing director. All charitable contributions should be publicly disclosed.

 

Your Responsibilities 

It is your responsibility to read, comprehend, and adhere to this policy. Preventing, detecting, and reporting bribery and corruption are obligations for all individuals working for us or under our authority.

Employees must avoid any activities that might suggest a breach of this policy and should promptly notify the managing director if they suspect a conflict or violation of this policy.

Any employee found in breach of this policy may face disciplinary action, including potential dismissal for gross misconduct. We retain the right to terminate relationships with other workers who breach this policy.

 

Record-Keeping

We must maintain financial records and effective internal controls that provide a legitimate business justification for payments to third parties. Employees must maintain written records of all accepted or offered gifts or hospitality, subject to managerial review.

All expenses related to hospitality, gifts, or payments to third parties must adhere to our expenses policy and include a clear rationale for the expenditure. All documents and records related to interactions with third parties, such as clients, suppliers, and business contacts, must be maintained with accuracy and completeness, without any off-book accounts to facilitate improper payments.

 

Reporting Concerns

You are encouraged to report any concerns about misconduct at the earliest opportunity. If you are unsure about whether an act constitutes bribery or corruption or have any other queries or concerns, please bring them to the attention of the managing director.

 

Responding to Bribery or Corruption

If you are offered a bribe, asked to make one, suspect future misconduct, or believe you are a victim of unlawful activity, inform the managing director immediately.

 

Protection

We support those who refuse to participate in bribery or corruption and those who report suspicions in good faith under this policy, even if they later prove unfounded.

We are committed to preventing detrimental treatment, such as dismissal or threats, towards individuals who raise concerns. If you believe you have suffered such treatment, notify the managing director. If unresolved, employees can use the company's Grievance Procedure.

 

Training and Communication

New employees receive training on this policy as part of their induction process. Existing employees undergo regular, relevant training on policy implementation and adherence. All employees are asked to formally confirm their compliance with this policy annually. Our zero-tolerance stance on bribery and corruption should be communicated to suppliers, contractors, and business partners at the beginning of our relationships and as necessary thereafter.

 

Policy Responsibility

The managing director is responsible for ensuring this policy aligns with our legal and ethical obligations and is followed by all under our control. The operations manager has primary responsibility for policy implementation, monitoring, and addressing interpretation inquiries. All management levels are responsible for familiarising their teams with this policy, ensuring understanding, and providing regular training.

 

Monitoring and Review

The operations manager will monitor policy effectiveness and conduct periodic reviews to assess its suitability, adequacy, and efficiency. Improvements will be implemented promptly when identified. Internal control systems and procedures will be regularly audited to ensure they effectively counteract bribery and corruption. All employees share responsibility for the success of this policy and should use it to report any suspected wrongdoing. Employees are encouraged to provide feedback on the policy and suggest improvements. This policy is not part of any employment contract and may be amended at any time.