Anti-Bribery Policy

Introduction

We are committed to the highest standards of ethical conduct and integrity in our business activities in the UK and overseas. This policy outlines our position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. We will not tolerate any form of bribery by, or of, our employees, agents or consultants or any person or body acting on our behalf. Our senior management team is committed to implementing effective measures to prevent, monitor and eliminate bribery, by taking the following action;

demonstrating a commitment to zero tolerance from the management team
carrying out risk assessments to determine the risk of bribery for the company
maintaining good internal controls and record-keeping
applying appropriate due diligence where business relationships change, or when new business develops, to identify possible causes of concern
effectively communicating the anti-bribery policy to everyone (employees and others associated with what we do)
securing the commitment of everyone in the team in the prevention and detection of bribery, and developing a culture in which bribery is unacceptable
providing guidance and training to everyone on how 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 providing guidance to the team so that they are aware of what to do should they discover a possible instance of bribery
annual monitoring and review of the effectiveness of the anti-bribery policy; updating as relevant to ensure that it remains effective

Bribery Act 2010

Under the Bribery Act 2010, a bribe is 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 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.

What is prohibited?

We prohibit employees or associated persons from offering, promising, giving, soliciting or accepting any bribe. The bribe might be cash, a gift or other inducement to, or from, any person or organisation, whether a public or government official, official of a state-controlled industry, political party or a private person or organisation, regardless of whether the employee or associated person is situated in the UK or overseas. The bribe might be made to ensure that a person or organisation improperly performs duties or functions (for example, by not acting impartially or in good faith or in accordance with their position of trust) to gain any commercial, contractual or regulatory advantage for the organisation in either obtaining or maintaining organisation business, or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or sub-contractors, agents or sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.

Records

Employees and, where applicable, associated persons, are required to take particular care to ensure that all organisation 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.

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.

Donations

We expressly prohibit the giving of donations to political parties. Any charitable donation must be consistent with our policy on charitable giving and with the knowledge and consent of the CEO. We expressly prohibit 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.

Risk management

We have established detailed risk management procedures to prevent, detect and prohibit bribery. We will conduct risk assessments for each of its key business activities on a regular basis and, where relevant, will identify employees or officers of the organisation who are in positions where they may be exposed to bribery.

We will identify high-risk areas, for example projects undertaken in high-risk countries, tenders for work and those working on high-value projects.

We will;

regularly monitor "at risk" employees and associated persons;
regularly communicate with "at risk" employees and associated persons;
undertake extensive due diligence of third parties and associated persons; and
communicate its zero-tolerance approach to bribery to third parties, including actual and prospective customers, suppliers and joint-venture partners.

Reporting suspected bribery

We depend on our employees and associated persons to ensure that the highest standards of ethical conduct are maintained in all its business dealings. Any concerns should be reported to the CEO as soon as possible, including;.

Issues that should be reported include;

any suspected or actual attempts at bribery;
concerns that other employees or associated persons may be being bribed; or
concerns that other employees or associated persons may be bribing third parties, such as clients or government officials.

Anti-bribery policy | Last Revised - 16 September 2020