37.1 The Company is committed to applying the highest standards of ethical conduct and integrity to its business activities. When acting on behalf of the Company you are responsible for maintaining the Company’s reputation and for conducting business honestly and professionally.
37.2 The integrity and reputation of the Company depends on the honesty, fairness and integrity brought to the job by everyone associated with the Company.
37.3 The Company will not tolerate any form of bribery, whether direct or indirect, by, or of, its employees, officers, agents or consultants or any persons or companies acting for it or on its behalf.
37.4 The Directors and senior management are committed to implementing and enforcing effective systems throughout the Company to prevent, monitor and eliminate bribery, in accordance with its obligations under the Bribery Act 2010.
37.5 The Company’s Anti-Bribery procedures apply to all employees, as well as agency workers, consultants and contractors.
37.6 All employees and any other individuals acting on behalf of the Company are required to familiarise themselves with and comply with the Company’s Anti-Bribery Procedures.
37.7 A bribe is defined as a financial advantage or other reward that is offered to, promised to, given to, or received by an individual or company to induce or influence that individual or company to perform its public or corporate functions or duties in an improper manner (i.e. not in good faith, not impartially, or not in accordance with a position of trust).
37.8 All employees and any other person acting on behalf of the Company are prohibited from offering, giving, soliciting or accepting any bribe, whether cash or other form of inducement to or from any person or company in order to gain any commercial, contractual or regulatory advantage for the Company in a way which is unethical or in order to gain any personal advantage, monetary or otherwise, for themselves or anyone connected with them.
37.9 The Company will continue to provide bona fide hospitality to clients and incur promotional expenditure. However, all such expenditure must be transparent, proportionate, reasonable and authorised in advance, in accordance with the Company’s anti-bribery procedures.
37.10 In the course of providing services to clients, or in dealings with suppliers, or any other person having similar connections to the Company, employees should under no circumstances accept money, gifts or other forms of reward with a value exceeding £10 without prior consent from The Finance Manager. All such reported gifts shall be recorded.
37.11 Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to The Finance Manager before proceeding.
37.12 Any breach of the Company’s Anti-Bribery procedures will normally be treated as Gross Misconduct.
37.13 Employees should also note that bribery is a criminal offence.
37.14 The Company will not conduct business with third parties including clients, suppliers, agents or representatives who are not prepared to support its anti-bribery objectives.
37.15 The Company depends on all employees, and those acting for the organisation, to assist in the prevention of bribery. Therefore, all employees and others acting for, or on behalf of, the Company are expected to report any suspected bribery to the Company following the Company’s Anti-Bribery procedures.
37.16 All employees will receive the support of the Company if they report of suspected bribery in good faith even if, following an investigation, it is found that no bribery took place.