Policies
1. Purpose
The purpose of this policy is to establish controls to ensure compliance with the Anti-Bribery Act 2010, and to ensure that the Company's business is conducted in a socially responsible manner.
2. Policy statement
Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. 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. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery. We are bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct.
Bribery and corruption are punishable for individuals by up to ten years' imprisonment and a fine. 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.
3. Scope
This policy applies to all individuals working at all levels and grades, including directors, project managers, senior supervisors, supervisors, employees (whether permanent, fixed term or temporary), consultants, contractors, apprentices, agency staff, or any other person associated with us, wherever located.
3.2 Bribes
Employees must not engage in any form of bribery, either directly or through any third party.
3.3 Gifts and hospitality
Employees must not offer or give any gift or hospitality which could be regarded as illegal or improper, or which violates the recipient's policies. Gifts exceeding £150 in value for each individual gift or £400 in value for each hospitality event (not to exceed a total value of £700 in any financial year) require written approval by a director.
4. Your responsibilities
You must ensure that you read, understand and comply with this policy. 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 employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
5. Record-keeping
We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties. You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.
10. Who is responsible for the policy?
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Managing Director has primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation.