1.1 This policy defines standards and guidelines in relation to adherence to the anti-bribery measures and standards that should apply to the acceptance and provision of gifts and hospitality. In particular, the policy is designed to comply with The Bribery Act 2010.
1.2 The policy is set out under the following headings:
- dealing with contractors, agents and business partners;
- giving gifts and hospitality;
- receiving gifts and hospitality;
- conflicts of interest policy;
- reporting bribery, corruption and suspected non-compliance with this policy.
2. Anti-bribery policy
2.1 Empteezy values its reputation for ethical behaviour and financial probity and reliability. The company recognises that any involvement in bribery is illegal and will reflect adversely on its image and reputation.
2.2 The company prohibits the offering, giving, soliciting or the acceptance of any bribe in whatever form to or from any person or company, public or private by any council member, member of staff, contractor, consultant, agent, overseas agent, external examiner and any non-employee service provider engaged on company business for whatever reason.
2.3 The prevention, detection and reporting of bribery is the responsibility of all staff.
3.Dealing with contractors, agents and business partners
3.1 The Bribery Act 2010 highlights two specific types of bribery that could lead to prosecution of the company.
- the liability to prosecution if a person associated with it bribes another person, where an associated person is one who performs services on or behalf of the organisation; and
- bribery of a foreign public official, where an official is one who holds a legislative, administrative or judicial position in a territory or country outside the UK.
3.2 This means that the company needs to take care to ensure that any contractors, agents or business partners acting on its behalf comply with the Act.
3.3 It is therefore essential that contractors and agents acting on the company’s behalf are made aware of the company’s anti-bribery policy, through the company’s terms and conditions or through the tendering process for larger contracts. In the case of international agents, reasonable due diligence must be carried out to ensure that they are not acting in a way that would compromise the company.
4. Giving gifts and hospitality
4.1 Staff may not, directly or through others, offer or give any, money, gift, hospitality or other thing of value to an official, employee or representative of any supplier, customer or any other organisation, if doing so could reasonably give the appearance of influencing the organisation's relationship with the company.
4.2 Staff may:
- give gifts of a nominal value with the prior permission of their line manager.
- with management approval, provide meals and other entertainment at venues outside the company, provided that the expenses are kept at a reasonable level. For the avoidance of doubt, the per capita cost of a meal should not in normal circumstances exceed £50 without permission of a line manager.
5. Receiving gifts and hospitality
5.1 An employee or any member of their family should not, directly or through others, solicit or accept money, gifts, hospitality or anything else that could influence or reasonably give the appearance of influencing the relationship with that organisation or individual.
5.2 Gifts or hospitality may not be accepted, irrespective of value, which might influence or be seen to influence such situations as, the award of business (contract) or the use of the company’s Intellectual Property or other assets, or to benefit personally or for the benefit of any person connected to that person.
5.3 Unless you have been informed otherwise you may accept:
- a gift of nominal value, such as an advertising novelty, when it is customarily offered to others having a similar relationship with that individual or organisation;
- customary meals or entertainment provided that the expenses are kept at a reasonable level.
6.1 All staff are required to comply with The Bribery Act 2010. The managing director is responsible for the company’s policy in relation to The Bribery Act 2010. Contact the MD if further guidance is required.
7. Conflicts of interest policy
7.1 A conflict of interest occurs when you advance a personal interest (or that of others with whom you are connected) at the expense of the company.
7.2 Reference should be made to the company’s policy on declarations of interest and the register of interests.
8. Reporting bribery, corruption and non-compliance with this policy
8.1 If you know of, or have good reason to suspect that, an unlawful or unethical situation or that you suspect that either an act of bribery or non-compliance to this policy has occurred; you should report the matter to your line manager in the first instance.