Overview

This policy outlines the responsibilities of the Company (and everyone who works for us) to adhere to the high standards we set for conducting our business affairs. You will find specific guidance in this policy on recognising and addressing bribery and corruption, whether in the UK or overseas. The standards detailed in this policy apply equally to activities conducted inside or outside the UK, we do not adopt ‘local standards’ overseas if they are lower than UK standards.

The policy applies to all employees, contractors, consultants, officers, interns, casual and agency workers, and anyone else under our control.

If you breach this policy, we may take disciplinary action against you, which could lead to dismissal for gross misconduct. You may also be committing a criminal offence.

Our commitment and your obligations

We are committed to integrity and fairness across all our operations. We do not tolerate bribery or corruption.

If you are employed or engaged by the Company, or are in any other way under our control, you must help prevent and detect bribery or corruption in our business.

You must report any conduct or activity that you believe or suspect amounts (or could in the future amount) to bribery or corruption to your manager or a Company director. Our Whistleblowing Policy has more information about raising these types of concerns.

Any report will be taken extremely seriously. We will not treat you unfavourably for having refused to become involved in bribery or corruption, or for flagging up your concerns to us in good faith. If you do suffer any negative treatment in this context, you must talk to your manager. If you are not satisfied that the issue has been resolved, you could raise a grievance under our Grievance Policy.

You must not threaten or otherwise treat badly anyone who refuses to become involved in bribery or corruption, or who has reported or is considering reporting a bribery or corruption-related issue to us.

What is bribery?

We define bribery as a reward or inducement for acting improperly, illegally or unethically to gain an advantage, whether personal, commercial, or regulatory. You do not need to have actually given or received the reward or inducement for this to amount to bribery.

A bribe does not need to involve money. Offering hospitality, entertainment or gifts can also be classed as bribery if the purpose is to exert influence.

You could face up to 10 years in prison for offering, promising, giving, asking for, or accepting a bribe, as this is a criminal offence. We may as a Company also face sanctions if we don’t stop bribery taking place. This can include an unlimited fine.

This list includes the most common actions we consider to be bribery, but it doesn’t cover everything. You must not become involved in any of these things, or allow anyone else to become involved in them on your behalf:

• Promising, offering or giving money, hospitality or gifts in the expectation of receiving a business advantage, or because you have already received that advantage.
• Accepting or giving hospitality or gifts in the course of commercial negotiations of any kind, including tender processes, if there is any uncertainty about whether doing so could have an impact on the outcome.
• Accepting money, gifts or hospitality from anyone you suspect is seeking a business advantage in return.
• Accepting hospitality that is excessively extravagant for the context in which it is offered.
• Offering gifts to government or other officials, political parties, and individual politicians.