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Anti-Bribery Policy

This policy applies to all permanent and fixed-term staff employed by the Company, and any contractors, consultants or other persons acting under or on behalf of the Company.

The company will not:

  • Make contributions of any kind with the purpose of gaining any commercial advantage.
  • Provide gifts or hospitality with the intention of persuading anyone to act improperly, or to influence a public official in the performance of their duties.
  • Make, or accept, “kickbacks” of any kind.

The company will not:

  • Keep appropriate internal records that will evidence the business reason for making any payments to third parties.
  • Encourage employees to raise concerns about any issue or suspicion of malpractice at the earliest possible stage.
  • See that anyone raising a concern about bribery will not suffer any detriment as a result, even if they turn out to be mistaken.

Employee Responsibility

Employees must not:

  • Accept any financial or other reward from any person in return for providing some favour.
  • Request a financial or other reward from any person in return for providing some favour.
  • Offer any financial or other reward from any person in return for providing some favour.

Gifts and Hospitality

This policy does not prohibit giving and receiving promotional gifts of low value, or normal and appropriate hospitality.

Receiving Business gifts:

  • Receiving promotional gifts of low value is normal and appropriate; however, gifts with a value exceeding £25.00 may not be accepted without approval. Any gift offered and then refused because of its value, must be reported to the Company.

Offering Business gifts:

  • Business gifts are primarily aimed at thanking customers and suppliers for their custom and loyalty, only authorised gifts may be given.

Receiving Hospitality:

The acceptance of corporate hospitality must be transparent; all invitations must be reported to the company before an employee accepts any invitation. The following areas are exempt while attending conferences, seminars, sponsored by third parties.

  • business and travel expenses incurred
  • normal business lunches and meals

Offering gifts and hospitality:

  • Company hospitality is primarily aimed at thanking customers and suppliers for their custom and loyalty. All hospitality events must have approval.

Donations to organisations:

  • No donations should be made to charities, political parties or other organisations without approval.