Anti-Bribery


Definition

Bribery is the giving or accepting of gifts, money, hospitality or other favours in return for providing something of value to or from another person. The purpose of this policy is to set out our policy to combat bribery.

You are not permitted to:

  • accept any financial or other benefit from any person in return for providing a favour;
  • request a financial or other benefit from any person in return for providing a favour;
  • offer any financial or other benefit to any person in return for providing a favour.

Any employee who is concerned that he or she is potentially being bribed should report this matter to management immediately.

Gifts

From time to time, clients, suppliers or other persons might offer you a gift. All gifts, however small, must be reported to your line manager. We may require that the gift be returned to the person who gave it. If this is the case, we will write to the giver of the gift explaining the reasons why the gift cannot be accepted.

Hospitality

From time to time, clients, suppliers or other persons might invite you to a hospitality event. All such invitations must be reported to your line manager. Permission must be given by your line manager before you accept any invitation of hospitality.

Offering gifts and hospitality

If a gift is authorised by your line manager you are entitled to give it to the appropriate individuals. A record must be kept of all gifts given.

We may run hospitality events, primarily aimed at thanking clients and suppliers for their custom and loyalty. You must not organise any hospitality event without seeking authority from management.

Responsibilities of managers

Deputy Managers are responsible for keeping a record of all gifts and hospitality that are offered and/or received by employees reporting to the manager. If Deputy Managers are concerned about any actions, they should contact the Managing Director immediately for advice.

Disciplinary action

Any employee found to have offered or accepted a bribe or hospitality in contravention with the terms of this policy will face disciplinary action which could include dismissal for gross misconduct.