Anti Bribery HB

Sections:

• Anti-bribery policy

Anti-bribery policy

1. PRINCIPLES
   1. The Employer values its reputation for ethical behaviour. The Employer aims to ensure compliance with all anti-bribery laws and regulations. Bribery is giving someone a financial or other advantage to induce them to perform their functions or activities improperly, or to reward them for having already done so.
   2. An employer will also be liable for failing to implement adequate procedures to prevent bribery by officers, employees, business partners and agents. It is therefore important that all persons (employees, officers, business parties and agents) familiarise themselves with and adhere to this policy.
   3. It is The Employer’s policy to conduct business in an honest way, and without the use of corrupt practices or acts of bribery to obtain an unfair advantage. The Employer will apply a ‘zero tolerance’ approach to any acts of bribery or corruption by any employees, officers, business partners or agents.
   4. Our anti-bribery principles are:
      • The offer, gift, solicitation, or acceptance of bribes (whether cash or any other inducement) to any person or company, wherever they are situated, by any employee, agent or other person or body acting on behalf of The Employer, in order to gain any commercial, contractual or other advantage is strictly prohibited;
      • No company officer, employee, business partner, or agent may offer payments (or anything else of value) to other parties to make those parties act in a manner that will assist The Employer in obtaining or retaining business;
      • No company officer, employee, business partner, or agent may request, agree to receive, or accept payments (or anything else of value) except in accordance with this policy;
      • The Employer operates a zero-tolerance approach to corruption by any officers, employees, business partners or agents working on its behalf; and
      • The Employer requires any officers, employees, business partners or agents to report any suspicious activity that may violate this policy.
   5. Any employee found to have violated this policy and procedures will be subject to disciplinary action, which may include summary dismissal. Any failure to report known or suspected violations may also lead to disciplinary action.
2. GIFTS, ENTERTAINMENT, AND HOSPITALITY
   1. Gifts, entertainment, and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, or invitations to events, functions, or other social gatherings, in connection with matters related to The Employer’s business.
   2. Gifts, entertainment, and hospitality can amount to bribery if they are of a nature or scale which shows they were given with the intention of inducing improper conduct from the recipient. Gifts and hospitality are allowed if provided simply to improve a relationship and/or network provided they are reasonable and proportionate.
   3. In order to provide clear guidance The Employer has adopted the following non exhaustive framework for the treatment of gifts and entertainment, whether given to other parties or received:
      • Business gifts that can be accepted can only be of insignificant/nominal value (such as a bottle of wine, flowers, chocolates, or branded merchandise). Any other gifts of more significant value should be discussed with your Line Manager and then refused or returned;
      • Offering or accepting a gift in the form of cash, or cash equivalent vouchers, is strictly prohibited;
      • ‘Quid pro quo’ arrangements (something offered for something in return) are strictly prohibited;
      • All gifts and hospitality involving travel and overnight accommodation requires prior approval from Line Managers;
      • Gifts or hospitality which could influence or appear to influence decisions made on behalf of The Employer should be refused;
      • The acceptance and offer of casual entertainment such as business lunch/dinners, is acceptable within reasonable bounds, as long as it is a normal and appropriate extension of business courtesy;
      • Employees must ensure that offering or accepting a gift or hospitality does not create or appear to create a conflict of interest for those involved;
      • Employees should not offer unjustified advantages to others, directly or indirectly, in connection with business dealings either in monetary form or as some other advantage;
      • Employees should avoid making gifts that could create an appearance of impropriety. No gifts should be given to public officials or other civil servants.
      • Customer and supplier hospitality should not be offered as an incentive for the recipient to make a favourable decision.
      • No donations should be made to any person, firm, or company on behalf of The Employer without the prior written authorisation of your line manager. Donations to political parties and charities which are directly linked to business and/or gaining a business advantage are strictly prohibited.
      • This is guidance only and each case should be considered on an individual basis. Employees should exercise prudence at all times and The Employer recognises that decisions as to what is acceptable may not always be easy. In the event of any doubt, always consult your line manager for guidance.
3. GIFTS AND ENTREUPANEUR REGISTER
   1. The Employer values transparency and will maintain a gifts, entertainment, and hospitality register. Any form of gift which exceeds a nominal value, and entertainment or corporate events of any value, must be appropriately recorded in the register.
   2. In the event that an impermissible gift, entertainment, or hospitality has been given or accepted, this transaction must still be recorded in the register.
4. COMPLAINT’S PROCEDURE
   1. The prevention, detection and reporting of bribery is the responsibility of all employees. If you feel that any action taken by The Employer or any individual has contravened this policy you should, in the first instance, contact your line manager to discuss, or if the suspected contravention is by your line manager, their line manager.