Anti-bribery

Our anti-bribery policy

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.

Who must comply with this policy?

This policy applies to everyone working for us including employees at all levels, including employees, agency workers, subcontractors, external consultants, third-party representatives and suppliers.

What is bribery?

‘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, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

Bribery includes offering, promising, giving, accepting or seeking a bribe.

All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with a Director.

Specifically, you must not:

• 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
• 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
• 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

You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

Gifts and hospitality

This policy does not prevent the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our reputation, or marketing our services.

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).

Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. They must not include cash or vouchers, or be given in secret. Gifts must be given in our company name, not an individual’s name.

Promotional gifts of low value such as branded stationery may be given to or accepted from existing clients, suppliers and subcontractors.

Record-keeping

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.

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.

How to raise a concern

If you are offered a bribe or are asked to make one, or if you suspect that any bribery, corruption or other breaches of this policy has occurred or may occur, you must notify a Director as soon as possible.

Policy review

This policy is reviewed annually and was last updated in Feb 2023.