This Policy addresses the two general offences contained within The Bribery Act 2010, this covers the requesting, agreeing to receive or accepting of a bribe (passive bribery) and the offering, promising or giving of a bribe (active bribery).
The Act sets out two additional offences that specifically address commercial bribery:
A new form of corporate liability for failing to prevent bribery on behalf of a commercial organisation.
The offence relating to bribery of a foreign public official in order to obtain or retain business or an advantage in the conduct of business.
The Company has nominated the Managing Director as the person responsible for this policy and actions.
Our policies, procedures, rules and frameworks relating to the Bribery Act are contained in our Staff Handbook and form part of each staff member’s terms of employment. Our policies are briefed out to staff at induction and updates are communicated at team meetings, via memo and staff notice boards and via periodic team briefings. Team briefings are held any time that there is an instance of non-compliance, changes in legislation or changes in company policy.
Senior Level Commitment
The senior management is committed to ensuring that our day to day activities are conducted without bribery: this includes passive, active, or any additional types of bribery by any member carrying out activities on behalf of the Company
The Company has specific rules and procedures in place to significantly reduce the risk of bribery or corruption. These include existing mechanisms in place to control Company expenditure, subcontractors, accounts or commercial contracts. A documented system of authorised signatories and company expenditure limits are in place to reduce the risk of any significant transactions.
Due diligence must be undertaken by any subcontractors or consultants working for and on behalf of the Company. A risk assessment and analysis has been carried out on such bribery being committed: it is likely that, because of our strict procedures, all parties acting on behalf of our Company are genuine and can be trusted to do business in a transparent and honest manner.
The Company considers genuine hospitality as Company expenditure that is reasonable. Invitations to attend high profile events, sporting events or other desirable hospitality may be accepted should the circumstance reflect good relations, provided the activity is authorised by a line manager and is reasonable to support the activities of the Company.
Monitoring and Review
This policy will be subject to monitoring and reviews by senior management to ensure that the risks faced and the effectiveness of the policy are a reflection of any updated legislation.