Last Updated August 2021
This policy applies to all employees and officers of the Company, and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, the Company ("associated persons”) within the UK and overseas. Every employee and associated person acting for, or on behalf of, the Company 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 and may cause serious damage to the reputation and standing of the Company.
The Company may also face criminal liability for unlawful actions taken by its employees or associated persons under the Bribery Act 2010. 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 by the Company.
This policy covers:
The Company is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. This policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. The Company 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 Company is committed to complying with the Bribery Act 2010 in its business activities in the UK and overseas.
Under the Bribery Act 2010, 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 in the course of a person’s employment, or on behalf of another company 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 under the Bribery Act 2010 if:
All employees and associated persons are required to comply with this policy, in accordance with the Bribery Act 2010.
The Company prohibits employees or associated persons 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 company, 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 company 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 any commercial, contractual or regulatory advantage for the Company in either obtaining or maintaining Company business, or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.
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 company 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 into any contract, arrangement or relationship with a potential supplier of services, agent, consultant or representative.
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.
The Company prohibits its employees or associated persons from making or accepting any facilitation payments. These are payments made to private individuals, companies or government officials to speed 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 the Company under the Bribery Act 2010, 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.
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 to the CEO.
If the public official provides written details, the CEO will consider the nature of the payment. Local legal advice may be sought by the Company.
If it is concluded that the payment is a legitimate fee, for example part of a genuine fast-track process, or is permitted locally, the Company will authorise the employee to make the payment.
Where the CEO considers that the request is 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 the Company and the UK embassy.
The Company 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, he/she should report it the CEO using the reporting procedure set out in this policy and in accordance with the Company's whistleblowing policy.
The Company permits corporate entertainment, gifts, hospitality and promotional expenditure that is undertaken:
Provided that it is:
The Company 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.
Employees and, where relevant, associated persons should submit requests for proposed hospitality and promotional expenditure well in advance of proposed dates to the CEO.
Employees are required to set out in writing on email:
The Company will approve business entertainment proposals only if they demonstrate a clear business objective and are appropriate for the nature of the business relationship. The Company 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 to the CEO. 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 general rule, small tokens of appreciation, such as flowers, chocolate 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 (via email) from the CEO is required, together with details of the intended recipients, reasons for the gift and business objective. These will be authorised only in limited circumstances.
Employees and, where applicable, associated persons must supply records and receipts, in accordance with the Company's expenses policy.
The Company does not make donations to any political parties or random charities. Employees and associated persons are not permitted to make any charitable and political donations to organisations on behalf of the Company. The Company may from time to time offer a charitable donation, this will be actioned and approved by the CEO.
This policy does not prohibit:
Any such practices must be proportionate, reasonable and made in good faith. Clear records must be kept - all transactions must be logged with the CEO.
The Company will conduct risk assessments for each of its key business activities on a regular basis and, where relevant, will identify employees or officers of the Company who are in positions where they may be exposed to bribery. Training will be given in these instances.
The Company will identify high-risk areas, for tenders for work and those working on high-value projects.
The Company will:
The Company 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 the Company and to remain vigilant in preventing, detecting and reporting bribery.
Employees and associated persons are encouraged to report any concerns that they may have to the CEO as soon as possible. Issues that should be reported include:
Any such reports will be thoroughly and promptly investigated by the CEO in the strictest confidence. Employees and associated persons will be required to assist in any investigation into possible or suspected bribery. The Company may ask an impartial third party to investigate on their behalf.
Employees will also be required to comply with the Company's whistleblowing policy.
Employees or associated persons who report instances of bribery in good faith will be supported by the Company. The Company will ensure that the individual is not subjected to detrimental treatment as a consequence of his/her 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 to the CEO.
The Company 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. The Company 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. The Company may terminate the contracts of any associated persons, including consultants or other workers who act for, or on behalf of, the Company who are found to have breached this policy.
The Company may also report any matter to the relevant authorities, including the Director of Public Prosecutions, Serious Fraud Office, Revenue and Customs Prosecutions Office and, or, the police. The Company will provide all necessary assistance to the relevant authorities in any subsequent prosecution.
The Company will regularly communicate its anti-bribery measures to employees and associated persons. The whole management team and the CEOs are responsible for the implementation of this policy, and will monitor and review the implementation of this policy and related procedures on a regular basis, including reviews of internal financial systems, expenses, corporate hospitality, gifts and entertainment policies.
All staff are required to complete anti-corruption and bribery online training.
The Company reserves the right to amend and update this policy as required. For the avoidance of doubt, this policy does not form part of employees’ contracts of employment.
