Anti-bribery and corruption policy

Introduction

We are committed to conducting all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

This policy sets out our position on any form of bribery and corruption and provides guidelines aimed at:

• ensuring compliance with anti-bribery laws, rules and regulations, not just within the UK but in any other country within which we may carry out our business or in relation to which its business may be connected;
• enabling employees and persons associated with us to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether by themselves or others;
• providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with;
• creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption.

Who must comply with this policy?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

What is bribery

Bribe means a financial or other inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

Bribery includes offering, promising, giving, accepting or seeking a bribe.

All forms of bribery are strictly prohibited. We recognise that industry practices may vary from country to country or from culture to culture and what is considered unacceptable in one place may be normal or usual practice in another. Nevertheless, you must adhere to all aspects of this policy at all times and if you are unsure about whether a particular act constitutes bribery, please check with your manager.

Your responsibilities

You are required to:

• comply with this policy;
• comply with any anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which you might be expected to conduct business;
• act honestly, responsibly and with integrity;
• operate in an ethical, professional and lawful manner at all times;
• report to your line manager any knowledge or suspicion you may have that you, or anyone else acting on our behalf, is involved in or planning any act which may constitute bribery.

Specifically, you must not:

• give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
• accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
• give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
• threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

Please be aware that you can be held personally responsible for any such offence.

Gifts and hospitality

This policy does not prohibit the giving or accepting of reasonable and appropriate gifts or hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

Gifts must:

• Be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift;
• Not include cash or cash equivalent (such as vouchers);
• No be given in secret;
• Must be given in our name, not your name.
• Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

Record-keeping

You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for the expenditure.

All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.

How to raise a concern

If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.