Anti-Bribery Policy

Date of next review: January 2027

Record of Amendments

• Date of Amendments: Created March 2017
• Review: February 2020 – No changes

This policy does not form part of any employee's contract of employment and we may amend it at any time.

Introduction

The Organisation is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on the Organisation’s behalf is responsible for maintaining the Organisation’s reputation and for conducting the Organisation’s business honestly and professionally.

The Organisation considers that bribery and corruption has a detrimental impact on business by undermining good governance.

The Organisation carries out business in a transparent and ethical way, ensuring we deliver an excellent service to our customers.

Policy Statement

The Organisation does not tolerate any form of bribery, whether direct or indirect, by, or of, its employees, contractors, or any person or companies acting for it or on its behalf. The Directors are committed to implementing and enforcing effective systems throughout the Organisation to prevent, monitor and eliminate bribery, in accordance with the Bribery Act 2010.

The anti-bribery policy applies to all employees, including agency workers, consultants and contractors. All employees and other individuals acting for the Organisation are required to familiarise themselves and comply with the organisation’s anti-bribery policy with immediate effect.

Types of Bribery

The legal definition

An active bribe is defined in section 1 of the Bribery Act 2010 as a financial or other advantage offered, promised or given to persuade a person to perform a relevant function or activity improperly or to reward him or her for doing so. Section 2 defines a passive bribe as requesting, agreeing to receive or accepting a bribe. A bribe takes place even where the advantage offered is to be provided to a third party.

A person has performed a function improperly where he or she has not met an expectation that he or she would act in good faith, impartially, or in accordance with a position of trust.

A relevant function or activity includes state or public functions, those connected with a business or those performed in the course of employment, or on behalf of a company or other person. Bribery in both the public and private sectors is covered.

The Bribery Act 2010 creates three further specific offences of commercial bribery. These apply to all commercial organisations, including companies, partnerships and incorporated bodies that carry on a business or part of a business in the UK (including those with charitable, educational or public functions):

• Section 6 – bribery of a foreign public official;
• Section 7 – failure of company to prevent bribery by associated person;
• Section 14 – offences under s.1 and 6 by corporate bodies.

Dealing with Incidents of Bribery

Employees and others acting for or on behalf of the Organisation are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments.

As part of its anti-bribery measures, the Organisation is committed to transparent, proportionate, reasonable and legitimate hospitality and promotional expenditure. Such expenditure must be authorised in advance, by a Director.

A breach of the Organisation’s anti-bribery policy by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal.

Employees and other individuals acting for the Organisation should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for the Organisation.

The Organisation will not conduct business with service providers, agents or representatives that do not support the Organisation’s anti-bribery objectives. The Organisation reserves the right to terminate its contractual arrangements with any third parties acting for, or on behalf of, the Organisation with immediate effect where there is evidence that they have committed acts of bribery.

The success of the Organisation’s bribery measures depends on all employees, and those acting for the Organisation, in taking individual responsibility in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on behalf of, the Organisation are encouraged to report any suspected bribery in accordance with the procedures set out in the anti-bribery policy. The Organisation will support any individual(s) who make such a report, provided that it is made in good faith.

Reporting Procedure

Any employee or person acting on behalf of the Organisation must report, in writing, any concerns, suspicions or evidence of bribery to a Director or Manager immediately.

Once received, the Organisation will instigate a formal investigation to ascertain the facts.

Please note an investigation may involve counter fraud or the police.

Action following the investigation will be as follows:

• No further action to be taken
• Action taken via the disciplinary procedure and/or
• Action taken under criminal proceedings