In 2011 the UK Government implemented laws to make bribery in any business operation illegal. This policy is designed so you can understand the implications of the law and to assist you with any decisions with which you may be faced. It provides guidance but is not a comprehensive statement of legal requirements. It is intended to clarify most situations and to flag up ones that may require more senior intervention or further legal guidance.
Principally, we require you to act honestly and with integrity at all times and in doing so you will be complying with this policy and with the law.
What is bribery?
If someone seeks to influence you to act so that you breach trust, lack impartiality or perform in bad faith (ie act improperly) then you need to be on your guard. If they seek to do so by offering, promising or giving an advantage to you (such as cash or items of significant value) then that is bribery. Bribery also occurs if you request, agree to receive or actually receive such an advantage. Such exchanges are illegal.
Reasonable and proportionate gifts as a token of appreciation or as part of facilitating normal business relationships are acceptable; the key is that they must not be an inducement to act improperly.
Employees who influence or make decisions on our behalf are more vulnerable and if you are uncomfortable with any form of influence you should report it to the Managing Director.
Gifts and hospitality
Typical examples of gifts of proportionate value as appreciation would be a bottle of wine, flowers, or chocolates either at Christmas or as a genuine “thank you”. These are entirely acceptable. If you are in doubt about the proportionality of any gift you should discuss the matter with the Managing Director.
Hospitality is defined as where the company providing the hospitality is present (say a buffet lunch at an exhibition) and, where this level of hospitality falls within our normal business relationship, it would be acceptable. Hospitality which is disproportionate may be seen to be influencing impartiality and is prohibited under this policy. Please refer any such offers to the Managing Director.
Where the company providing the hospitality is not present, for example if a restaurant voucher is given, then this is a gift, not hospitality. If you are in doubt about the proportionality of any gift, you should discuss the matter with the Managing Director.
If you are involved in deciding on a supplier or in any form of tendering process then gifts and hospitality (even if proportionate) must not be accepted and, if offered, should be politely declined and referred to the Managing Director.
Where a service is being carried out by a third party, for example distributors, a term requiring them to comply with all anti-bribery and corruption legislation should be included in the contract.
Conflicts of interest
You should avoid any situation where you might benefit personally from decisions you take or influence on behalf of Lara Nichols. Where a conflict of interest could arise the relevant decision must be referred to the Managing Director.
Breaches of this policy
Failure to comply with this policy may result in investigations, disciplinary action and potentially dismissal. You could also be subject to other civil or criminal sanction.