31.1 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 wherever we operate and to implement and enforce effective systems to counter bribery.
31.2 In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
31.3 This policy applies to all individuals working at all levels and grades.
What is bribery?
31.4 A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
What is not acceptable?
31.5 It is not acceptable for you (or someone on your behalf) to:
31.5.1 Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.
31.5.2 Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure.
31.5.3 Accept payment from a third party that you know, or suspect is offered with the expectation that it will obtain a business advantage for them.
31.5.4 Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return.
31.5.5 Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy.
31.5.6 Engage in any activity that might lead to a breach of this policy.
Facilitation payments and kickbacks
31.6 We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
31.7 We do not make contributions to political parties and we only make charitable donations that are legal and ethical under local laws and practices.
31.8 You must ensure that you read, understand and comply with this policy.
31.9 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 workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
31.10 You must notify us immediately if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
31.11 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.
31.12 You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review. 13 You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted to management and specifically record the reason for the expenditure.
31.14 All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness.
How to raise a concern
31.15 You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. Concerns should be reported.
What to do if you are a victim of bribery or corruption
31.16 It is important that you tell us as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
31.17 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
31.18 We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. If you believe that you have suffered any detrimental treatment, you should inform us immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.