Anti-Bribery & Corruption Policy

Published: 15th June 2024

1. Introduction

1.1 Bribery and corruption remain a major issue in world trade, despite the many dedicated efforts to prevent them. Our legal obligations are primarily governed by the Bribery Act 2010. That Act affects us, as a UK company, if bribery occurs anywhere in our business.

1.2 Involvement in bribery and corruption exposes the Company and relevant individuals to a criminal offence. It will also damage our reputation and the confidence of our customers, suppliers and business partners.

1.3 The Company’s position is simple: the Company conducts its business to the highest legal and ethical standards. The Company will not be party to corruption or bribery in any form. Such acts would damage the Company’s reputation and expose the Company, and its employees and representatives, to the risk of fines and imprisonment. If at any point you are unsure about whether a particular act constitutes bribery, you should raise it with your line manager or the HR department.

1.4 We run our business with integrity and in an honest and ethical manner. All of us must work together to ensure that our business remains untainted by bribery or corruption. This policy is a crucial element of that effort and is the personal responsibility of the CEO. It has the full support of the Company’s board, and it is the CEO’s commitment to make sure it is followed. However, the policy needs the full support of our staff to make it work.

1.5 This policy sets out the steps all of us must take to prevent bribery and corruption in the Company’s business in order to comply with relevant legislation and the Company’s requirements. It does not form part of any employee’s contract of employment and may be amended at any time.

2. What are bribery and corruption?

2.1 A ‘bribe’ is a financial or other advantage offered, promised, requested or given to induce a person to perform a relevant function or activity improperly, or to reward them for doing so. This may include cash or cash equivalents, gifts, hospitality, entertainment, services, loans, preferential treatment, discounts, or similar benefits. The timing of the bribe is irrelevant, and payments made after the event are still included. It is not necessary for the individual or organisation to receive any benefit.

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

2.3 ‘Corruption’ is the misuse of office or power for private gain.

2.4 All forms of bribery and corruption are strictly prohibited. No person must:

  • 2.4.1 Give or offer any payment, gift, hospitality or other benefit in expectation of a business advantage or as a reward for business received;
  • 2.4.2 Accept any offer from a third party where there is knowledge or suspicion that it is made in expectation of a business or personal advantage;
  • 2.4.3 Give or offer any facilitation payment to a government official in any country.

2.5 No person must threaten or retaliate against another who refuses to offer or accept a bribe or who raises concerns about possible bribery or corruption.

2.6 It does not matter whether bribery occurs in the UK or abroad, or whether it is direct or indirect.

3. Who can be involved in bribery and in what circumstances?

3.1 Bribery and corruption may be committed by anyone working for or on behalf of the Company, including employees, officers, directors, representatives, suppliers, and customers.

3.2 This policy applies to all individuals listed above.

3.3 Bribery can occur in both public and private sectors, often involving individuals who can influence business decisions.

4. The legal position on bribery and corruption

4.1 Bribery and corruption are criminal offences in most countries where we operate. UK-incorporated companies are subject to the Bribery Act 2010.

5. Responsibility for this policy

5.1 The Founding Partners have overall responsibility for this policy.

6. Gifts and hospitality

6.1 Staff must not solicit gifts or hospitality in the course of their work.

6.2 Staff must not offer or receive gifts or hospitality that are unduly lavish, inappropriate, or could be seen as an inducement or reward. This includes:

  • 6.2.1 Gifts exceeding £100 in value;
  • 6.2.2 Hospitality exceeding £100 in value;
  • 6.2.3 Cash or cash-equivalent gifts;
  • 6.2.4 Gifts or hospitality given or received in secret;
  • 6.2.5 Gifts or hospitality given or received in an individual’s name rather than the Company’s.

7. Records

7.1 Full and accurate records of all financial dealings must be kept. Transparency is essential.

7.2 All gifts and hospitality given or received must be declared and recorded in writing, and expenses submitted in line with Company policy.

7.3 All financial records must be accurate, complete, and properly maintained. No accounts may be kept off book.

8. Monitoring

8.1 The Partners will monitor this policy regularly to ensure compliance.

9. What to do if you think something is wrong

9.1 Everyone has a responsibility to report suspected bribery or corruption. Concerns should be raised in accordance with the Whistleblowing Policy as soon as possible. Reports may be made anonymously.

10. Compliance with this policy

10.1 The Company takes compliance very seriously. Failure to comply puts both individuals and the Company at risk.

10.2 Individuals may commit a criminal offence by failing to comply with this policy.

10.3 Breaches of this policy may result in disciplinary action, including dismissal for gross misconduct. Non-employees may have their contracts terminated immediately.

10.4 If you are unsure about any aspect of this policy, contact your line manager or the HR department.