Anti-Bribery & Corruption Policy
The Anti-Bribery and Corruption is part of our Code of Business Ethics which sets out the company’s expectations and boundaries of what is acceptable and not acceptable behaviour.
This Code represents a framework to help guide decision-making and it is continually reviewed to ensure that the company’s standards are aligned with the current thinking on best practice in business ethics and reputation risk management.
Bribery and Corruption
Corruption damages both corporate and individual reputations, is a criminal offence in most jurisdictions.
It is against the law in the United Kingdom (Bribery Act 2010) and other jurisdictions and, in breach of our policy, to promise, offer to, or accept, agree to receive from anyone, a bribe, favour, facilitation payment or gift ‘in kind’ or similar incentive to gain business advantage.
Business Communications has in place effective procedures to mitigate the risk of involvement in bribery. It also has a duty to provide the policies and procedures to enable people to comply with the law when working with/for us.
Employees and contractors have individual responsibility for ensuring that company policy and procedures are followed.
Gifts and Hospitality
What is perceived as an ‘acceptable’ business gift in one culture may be considered or be an actual bribe in another? Offering disproportionate hospitality to secure business advantage is unethical and may be construed by the authorities as a bribe.
Employees, business representatives and suppliers must make themselves aware of the policy and of the need to notify a company senior manager if gifts or hospitality are offered or received which fall outside this Policy.
Employees and contractors have individual responsibility for recording the receipt and giving of any Gifts & Hospitality in the register, including seasonal gifts, which is subject to regular audit.
Record Keeping
The keeping of appropriate and accurate records of all business transactions is an important element of the compliance process. Employees and intermediaries must keep books, records, and accounts which, in reasonable detail, accurately reflect their business transactions and dealings with and on behalf of the company.
Unacceptable Behaviour
- Promising to offer, give, accept, receive, agree to receive a bribe, favour or gift ‘in kind’ to a company, subcontractor or any private person, directly or through any third party whatsoever (such as an agent, family member) and / or
- Participating in any corrupt activity to secure or retain any business advantage or actual business on behalf of the company, regardless of custom and practice
- Unauthorised or excessive and inappropriate expenditure on entertaining our employees or contractors
- Offering or making facilitation payments on the behalf of the company
- Failing to report and escalate ethical risks and issues relating to your relationship with a company representative
Responsibilities
Business Communications has an obligation and the right to enforce its policies and mitigate the risk of criminal behaviour, by investigating alleged compliance breaches and applying sanctions where necessary. The company has a duty to disclose details of legal breaches, such as money laundering or bribery, to the appropriate authorities where necessary.
