The company directors will review this policy on an annual basis regarding effectiveness, legislative compliance, organisational changes and general improvements.

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Legislation - The Bribery Act 2010

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Bribery is generally defined as giving someone a financial or other benefit to encourage them to perform their activities improperly or to reward them for having already done so.  If a company is found to be in breach of the law it could face an unlimited fine and be excluded from tendering for government contracts.  Bribery and corruption is punishable for individuals by up to ten years imprisonment.

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Policy
The company is committed to preventing bribery and corruption, and all personnel - directors, employees and any other parties, e.g. contractors, acting on behalf of the company must not:

• Attempt to offer or make a payment of any kind to anyone to retain or obtain business for the company, or to gain a commercial advantage.

• Request, make, or accept an improper payment of any kind, or knowingly allow another person to accept a bribe in relation company business.

• Provide gifts or hospitality with the intention of persuading someone to act improperly, or to influence them in the performance of their duties.

• Accept gifts of a monetary nature or in the form of materials, equipment, services, facilities or anything else of value from any source, e.g. customers and suppliers. Such offers should be politely declined, except for:

  • Gifts of no monetary value associated with accepted business relationships, e.g. a desk calendar from a supplier.

  • Gifts received at Christmas time from suppliers, provided that they are shared with all company employees where practical.

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If in doubt seek advice from management.

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Transgressions will be dealt with in accordance with the disciplinary procedure.

Company responsibilities

The company will:

• Communicate the policy and undertake a review on an annual basis.

• Keep records concerning all payments made to, or received from, all parties associated with the business.

• Encourage employees to raise any concerns at the earliest opportunity and to ensure that any investigation is handled in confidence, with no retaliation if the matter is found to be invalid.

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Employee responsibilities
Adhere to the policy and report any suspicion of bribery or corruption to management.