Our organisation is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas.
This policy outlines our position on preventing and prohibiting bribery. Our organisation will not tolerate any form of bribery by, or of, its employees, agents or consultants or any person or body acting on its behalf. Senior management is committed to implementing effective measures to prevent, monitor and eliminate bribery.
The policy does not form part of your contract of employment, and we reserve the right to amend or withdraw it at any time.
This policy applies to all employees and officers of our organisation, and to temporary workers, consultants, contractors, agents, and subsidiaries acting for, or on behalf of, our organisation (“associated persons”) within the UK and overseas. Every employee and associated person acting for, or on behalf of, our organisation is responsible for maintaining the highest standards of business conduct.
Any breach of this policy is likely to constitute a serious disciplinary, contractual, and criminal matter for the individual concerned. All employees and associated persons are required to familiarise themselves and comply with this policy, including any future updates that may be issued from time to time.
This policy covers:
Our organisation is committed to complying with the Bribery Act 2010 in its business activities in the UK and overseas.
A bribe is a financial or other type of advantage that is offered or requested with the:
A relevant function or activity includes public, state or business activities or any activity performed during a person’s employment, or on behalf of another organisation or individual, where the person performing that activity is expected to perform it in good faith, impartially, or in accordance with a position of trust.
A criminal offence will be committed if:
Employees or associated persons are prohibited from offering, promising, giving, soliciting, or accepting any bribe. The bribe might be cash, a gift or other inducement to, or from, any person or organisation, whether a public or government official, official of a state-controlled industry, political party or a private person or organisation, regardless of whether the employee or associated person is situated in the UK or overseas.
The bribe might be made to ensure that a person or organisation improperly performs duties or functions (for example, by not acting impartially or in good faith or in accordance with their position of trust) to gain a:
This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or sub-contractors, agents or sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.
Employees and, where applicable, associated persons, are required to take particular care to ensure that all records are accurately maintained in relation to any contracts or business activities, including financial invoices and all payment transactions with clients, suppliers, and public officials.
Due diligence should be undertaken by employees and associated persons prior to entering any contract, arrangement, or relationship with a potential supplier of services, agent, consultant, or representative [in accordance with our procurement and risk management procedures].
Employees and associated persons are required to keep accurate, detailed, and up-to-date records of all corporate hospitality, entertainment or gifts accepted or offered.
Principle
Employees and associated persons conducting business on behalf of our organisation outside the UK may be at greater risk of being exposed to bribery or unethical business conduct than UK-based employees. Employees and associated persons owe a duty to our organisation to be extra vigilant when conducting international business.
Procedure
Employees and associated persons are required to cooperate with our risk management procedures and to report suspicions of bribery. While any suspicious circumstances should be reported, employees and associated persons are required particularly to report:
If an employee or associated person is in any doubt as to whether a potential act constitutes bribery, the matter should be reported (see below).
Principle
Employees or associated persons are prohibited from making or accepting any facilitation payments. These are payments made to government officials for carrying out or speeding up routine procedures. They are more common overseas. Facilitation payments are distinct from an official, publicly available fast-track process.
Facilitation payments, or offers of such payments, will constitute a criminal offence by both the individual concerned and our organisation, even where such payments are made or requested overseas. Employees and associated persons are required to act with greater vigilance when dealing with government procedures overseas.
Procedure
Where a public official has requested a payment, employees or associated persons should ask for further details of the purpose and nature of the payment in writing. If the public official refuses to give these, this should be reported immediately (see below).
If the public official provides written details, the nature of the payment will be reviewed and local legal advice may be sought.
If it is concluded that the payment is a legitimate fee, for example part of a genuine fast-track process, or is permitted locally, our organisation will authorise the employee to make the payment.
Where the request is considered to be for a facilitation payment, the employee or associated person will be instructed to refuse to make the payment and notify the public official that the employee or associated person is required to report the matter to our organisation and the UK embassy.
We will seek the assistance of the relevant employee in its investigation and may determine that the matter should be referred to the prosecution authorities.
If an employee or associated person has any other concerns about the nature of a request for payment, they should report it (see below) using the reporting procedure set out in this policy [and in accordance with our whistleblowing policy].
Principle
Our organisation permits corporate entertainment, gifts, hospitality, and promotional expenditure that is undertaken:
if it is:
We will authorise only reasonable, appropriate, and proportionate entertainment and promotional expenditure.
This principle applies to employees and associated persons, whether based in the UK or overseas. However, those with remits overseas will be given further training on the specific procedures that they are required to follow.
Procedure
Employees and, where relevant, associated persons should submit requests for proposed hospitality and promotional expenditure well in advance of proposed dates.
Employees are required to set out in writing:
We will approve business entertainment proposals only if they demonstrate a clear business objective and are appropriate for the nature of the business relationship. We will not approve business entertainment where it considers that a conflict of interest may arise or where it could be perceived that undue influence, or a particular business benefit was being sought (for example prior to a tendering exercise).
Any gifts, rewards or entertainment received or offered from clients, public officials, suppliers, or other business contacts should be reported immediately (see below). In certain circumstances, it may not be appropriate to retain such gifts or be provided with the entertainment and employees and associated persons may be asked to return the gifts to the sender or refuse the entertainment, for example where there could be a real or perceived conflict of interest. As a rule, small tokens of appreciation, such as flowers or a bottle of wine, may be retained by employees.
If an employee or associated person wishes to provide gifts to suppliers, clients or other business contacts, prior written approval is required, together with details of the intended recipients, reasons for the gift and business objective. These will be authorised only in limited circumstances. Please see below for how to request.
Employees and, where applicable, associated persons must supply records and receipts, in accordance with our expenses policy.
Charitable and political donations
Our organisation does not make donations to any political parties/charities. Employees and associated persons are not permitted to make any charitable and political donations to organisations on our behalf.
What practices are permitted?
This policy does not prohibit:
Any such practices must be proportionate, reasonable, and made in good faith. Clear records must be kept.
Principle
Our organisation has established detailed risk management procedures to prevent, detect and prohibit bribery. We will conduct risk assessments for each of its key business activities on a regular basis and, where relevant, will identify employees or officers of our organisation who are in positions where they may be exposed to bribery.
Procedure
Our organisation will identify high-risk areas, for example projects undertaken in high-risk countries, tenders for work and those working on high-value projects. Employees and associated persons are required to complete a bribery risk assessment when commencing a new project.
We will:
Principle
Our organisation depends on its employees and associated persons to ensure that the highest standards of ethical conduct are maintained in all its business dealings. Employees and associated persons are requested to assist our organisation and to remain vigilant in preventing, detecting, and reporting bribery.
Employees and associated persons are encouraged to report any concerns that they may have as soon as possible. Issues that should be reported include:
Procedure
A form is available to allow employees to record any incidents of suspected bribery. Any such reports will be thoroughly and promptly investigated by Director, Simon Hayward in the strictest confidence. Employees and associated persons will be required to assist in any investigation into possible or suspected bribery.
Employees will also be required to comply with our whistleblowing policy.
Employees or associated persons who report instances of bribery in good faith will be supported. We will ensure that the individual is not subjected to detrimental treatment because of their report. Any instances of detrimental treatment by a fellow employee because an employee has made a report will be treated as a disciplinary offence. An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, employees and associated persons should not agree to remain silent. They should report the matter immediately.
When an individual reports suspected instances of bribery, we will process any personal data collected in accordance with our data protection policy. Data collected from the point at which the individual makes the report is held securely and accessed by, and disclosed to, individuals only for the purposes of dealing with the report of bribery.
We will fully investigate any instances of alleged or suspected bribery. Employees suspected of bribery may be suspended from their duties while the investigation is being carried out. We will invoke its disciplinary procedures where any employee is suspected of bribery, and proven allegations may result in a finding of gross misconduct and immediate dismissal. We may terminate the contracts of any associated persons, including consultants or other workers who act for, or on behalf of, our organisation who are found to have breached this policy.
We may also report any matter to the relevant authorities, including the Serious Fraud Office and the police. We will provide all necessary assistance to the relevant authorities in any subsequent prosecution.
Our organisation will regularly communicate its anti-bribery measures to employees and associated persons. We will set up training sessions where applicable. Simon Hayward is responsible for the implementation of this policy.
This policy and related procedures will be monitored and reviewed on a regular basis, including reviews of internal financial systems, expenses, corporate hospitality, gifts, and entertainment policies.
Employees and those working for, or on behalf of, our organisation are encouraged to contact Director, Simon Hayward with any requests for approval and concerns they may have about bribery or suspected bribery. Suggestions, comments, or feedback about how to improve these procedures are also welcome.
To report, request or gain approval relating to this policy, please email info@Wardcon.net using subject: Anti-corruption Policy