We are committed to the highest standards of ethical conduct and integrity in our business activities in the UK and overseas. This policy outlines our position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. We will not tolerate any form of bribery by, or of, our employees, agents or consultants or any person or body acting on our behalf. Our senior management team is committed to implementing effective measures to prevent, monitor and eliminate bribery, by taking the following action;
Under the Bribery Act 2010, a bribe is a financial or other type of advantage that is offered or requested with the intention of inducing or rewarding improper performance of a function or activity; or knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity.
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 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 under the Bribery Act 2010 if;
We prohibit 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 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 any commercial, contractual or regulatory advantage for the organisation in either obtaining or maintaining organisation 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 organisation 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.
We expressly prohibit the giving of donations to political parties. Any charitable donation must be consistent with our policy on charitable giving and with the knowledge and consent of the CEO. We expressly prohibit the making of charitable donations where the purpose of the donation is to secure an advantage. All charitable donations must be made without expectation of reward.
We have 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 the organisation who are in positions where they may be exposed to bribery.
We will identify high-risk areas, for example projects undertaken in high-risk countries, tenders for work and those working on high-value projects.
We depend on our employees and associated persons to ensure that the highest standards of ethical conduct are maintained in all its business dealings. Any concerns should be reported to the CEO as soon as possible, including;.
Issues that should be reported include;
Anti-bribery policy | Last Revised - 16 September 2020