1. Introduction
The Company is committed to complying with the Bribery Act 2010 whilst operating under the highest
standards of ethical conduct and integrity in its business activities in the UK and overseas.
Under the Bribery Act 2010, a bribe is defined as 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 but is not limited to, 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:
- an employee or associated person acting for, or on behalf of, the organisation offers,
promises, gives, requests, receives or agrees to receive bribes; or
- an employee or associated person acting for, or on behalf of, the organisation offers, promises
or gives a bribe to a foreign public official with the intention of influencing that official in the
performance of their duties (where local law does not permit or require such influence); and,
- the organisation does not have the defence that it has adequate procedures in place to
prevent bribery by its employees or associated persons.
2. Scope of this policy
This policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with
the Bribery Act 2010. This policy covers:
- the main areas of liability under the Bribery Act 2010;
- the responsibilities of employees and associated persons acting for, or on behalf of, the
Company; and
- the consequences of any breaches of this policy.
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. The Senior Management are committed to implementing
effective measures to prevent, monitor and eliminate bribery.
This is achieved by:
- carrying out a risk assessment to ascertain the risk of bribery;
- undertaking due diligence procedures proportionate to the assessed risk of bribery
- instigating procedures proportionate to that risk;
- having good internal controls and record-keeping;
- securing the commitment of directors, managers and all staff to the prevention and detection
of bribery;
- developing a culture in which bribery is unacceptable;
- effectively communicating the anti-bribery policy to all staff;
- training all staff to recognise bribery so that they can avoid it and be alert to possible instances
of bribery;
- having clear procedures on what to do should bribery be suspected; and,
- monitoring and reviewing the effectiveness of the bribery procedures and updating them as
necessary to ensure that they remain effective.
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.
3. What is prohibited?
3.1 Offering bribes
The Company expressly prohibits any person employed by or associated with it from offering,
promising or giving any financial advantage or other reward to another person where it is intended
that the advantage will bring about improper performance by another person of a relevant function
or activity, or that the advantage will reward such improper performance.
The Company prohibits any person employed by or associated with it from offering, promising or
giving any financial advantage or other reward to another person where it is believed that the
acceptance of the advantage offered, promised or given in itself constitutes the improper
performance of a relevant function or activity.
3.2 Accepting bribes
The Company expressly prohibits any person employed by or associated with it from requesting,
agreeing to receive or receiving any financial advantage or other reward with the intention that a
relevant function should be performed improperly as a result of the advantage or as a reward for
performing the relevant function improperly. The improper performance of a relevant function in
anticipation of receiving financial advantage or other reward is also prohibited.
3.3 Bribing a public official
The Company expressly prohibits the bribing of a UK or foreign public official in order to obtain or
retain business or an advantage in the conduct of business.
3.4 Relevant functions and activities
Relevant functions and activities are any function of a public nature, any activity connected with the
business, any activity performed in the course of a person’s employment and activity performed by or
on behalf of a body of persons where the person performing that function or activity is expected to
perform it impartially, in good faith, or is in a position of trust by virtue of performing it.
3.5 Hospitality and business gifts
The Bribery Act 2010 does not seek to prohibit reasonable and proportionate hospitality, gratuities,
advertising, sponsorship and promotional or other similar business expenditure, as it is recognised
that this constitutes an established and important part of doing business. However, hospitality,
promotional and similar business expenditure can be used as bribes. The Company expressly prohibits
the giving and receiving of hospitality/business gifts and similar whenever these could affect or be
perceived to affect the outcome of business transactions and are not reasonable and bona fide
expenditures. The following procedures should be adopted in relation to hospitality and business
gifts:
- All offers of business gifts exceeding £40/€50 in value should be referred to a senior manager
and should only be accepted if clearance has been granted.
- Business gifts exceeding £40/€50 in value should not be made without the permission of a
senior manager. The provision of small Company branded promotional gifts, such as diaries,
pens or similar, will generally be regarded as acceptable.
- All business gifts made and the reason for the gift must be identified on the relevant expenses
form and authorised by a senior manager.
- All employees must declare hospitality, benefits or gifts received from third parties during the
course of their employment.
- All hospitality must be proportionate and reasonable and in line with the Company's
hospitality policy. Guidance should be sought from a senior manager as to whether the
planned hospitality is proportionate and reasonable.
- Records should be maintained of all hospitality provided and accepted, including cost and
reason for providing or accepting the hospitality.
- Quid pro quo arrangements are expressly prohibited.
- Cash gifts are expressly prohibited.
- The provision or acceptance of entertainment of a sexual nature is expressly prohibited.
- Acceptable hospitality and entertaining may include modest meals with people with whom
we do business (such as providing a modest lunch after a meeting) or the occasional provision
of or attendance at sporting or cultural events, provided that the intention is to build business
relationships rather than to receive or confer an advantage.
- Staff reviewing expense claims should be alert to the provision of hospitality/business gifts
that may be construed as a bribe.
- All concerns should be reported to the Anti-Bribery Committee.
3.6 New business, change in business and contracts with external parties
Where you develop or seek to develop new avenues for business or new contracts, or where the
nature of the business changes, you should inform your line manager of this in order that due diligence
and a risk assessment of the circumstances can be undertaken.
Where a business relationship with an external party is sought or newly established, or the nature of
the relationship is changed, appropriate due diligence must be exercised to ensure that there are no circumstances giving rise to a concern. That external party must also be made aware of this antibribery policy.
3.7 Facilitation payments
Facilitation payments are small bribes that are paid to speed up or facilitate government action.
Although they are commonplace in some foreign countries, they are regarded as bribes and are illegal
under the Bribery Act 2010. The Company expressly prohibits facilitation payments of any sort. Any
member of staff placed under pressure to make a facilitation payment should refer the matter to a
senior manager immediately or report their concern to the Anti-Bribery Committee.
3.8 Donations
The Company expressly prohibits the giving of donations to political parties. Any charitable donation
must be consistent with the Company’s policy on charitable giving and with the knowledge and
consent of a senior manager. The Company expressly prohibits 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.
4. Working Overseas
Employees and associated persons conducting business on behalf of the Company outside the UK may
be at greater risk of being exposed to bribery or unethical business conduct than UK-based employees.
Employees and associated persons owe a duty to the Company to be extra vigilant when conducting
international business, as the provisions of the Bribery Act and this policy still applies even if the
offence is committed overseas.
Employees and associated persons are required to cooperate with the Company's risk management
procedures and to report suspicions of bribery. While any suspicious circumstances should be
reported, employees and associated persons are required particularly to report:
- close family, personal or business ties that a prospective agent, representative or jointventure partner may have with government or corporate officials, directors or employees;
- a history of corruption in the country in which the business is being undertaken;
- requests for cash payments;
- requests for unusual payment arrangements, for example via a third party;
- requests for reimbursements of unsubstantiated or unusual expenses; or
- a lack of standard invoices and proper financial practices.
If an employee or associated person is in any doubt as to whether or not a potential act constitutes
bribery, the matter should be referred to the [email protected].
5. Records
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 in accordance with the Company's procurement and risk management procedures.
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.
6. Communication and Training
The Company will regularly communicate its anti-bribery measures to employees and associated
persons. The Company will set up training sessions where applicable. The Anti-Bribery Committee is
responsible for the implementation of this policy.
7. Monitoring and Reviewing
The Anti-Bribery Committee 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.
Employees and those working for, or on behalf of, the Company are encouraged to contact
[email protected] with any suggestions, comments or feedback that they may
have on how these procedures may be improved.
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.
8. Reporting concerns
All members of staff have a responsibility to prevent, detect and report all instances of bribery. Staff
should therefore be alert to the possibility of bribery. Anyone who has concerns regarding acts or
potential acts of bribery should email their concerns to [email protected]. If
email is not available, staff may write to the Anti-Bribery Committee c/o Andrews Sykes Group, St
David’s Court, Union Street, Wolverhampton WV1 3JE. Where possible, reports will be treated in
confidence.
The Company will investigate any potential breach in accordance with the disciplinary policy. The
ultimate sanction for a breach of the policy will be summary dismissal for gross misconduct.
Updated April 2023
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