Bribery & Corruption Policy

Introduction & Background

The Company values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:

setting out a clear anti-bribery policy,
establishing and implementing anti-bribery procedures as appropriate,
communicating this policy and any relevant procedures to employees and to others who will perform services for the Company,
undertaking appropriate due diligence measures before engaging others to represent the Company in its business dealings,
monitoring and reviewing the risks and the effectiveness of any anti-bribery procedures that are in place.

We do, as standard company practice, include a packet of company branded sweets with every shipment of goods.

Definitions

Fraud is theft by deception. It is any deliberate intent to permanently deprive a person or organisation of money or goods through the falsification of any records or documents.
Bribery is the accepting of gifts, money, hospitality or other favours in return for providing something of value to the briber
Corruption is where someone is influenced by bribery, payment or benefit in kind to unreasonably use their position to give some advantage to another.

Policy

Setting out a clear anti-bribery policy
Establishing and implementing anti-bribery procedures as appropriate
Communicating this policy and any relevant procedures to employees and to others who will perform services for the Company
Undertaking appropriate due diligence measures before engaging others to represent the Company in its business dealings
Monitoring and reviewing the risks and the effectiveness of any anti-bribery procedures that are in place

External Agencies

The company will not hesitate, whenever appropriate, to report concerns to the police and/or revenue agencies for investigation. The inclusion of external agencies are in addition to internal investigations and disciplinary action as necessary.

Warning Signs

Whilst by no means being proof on their own, the circumstances below may indicate fraud, and should therefore raise suspicions:

altered documents (correcting fluid, different pen or handwriting);
claim form details not readily checkable;
changes in normal patterns, e.g. of cash takings or travel claim details;
text erratic or difficult to read or with details missing;
delay in completion or submission of claim forms;
lack of vouchers or receipts in support of expense claims, etc;
employees seemingly living beyond their means;
employees under constant financial or other stress;
employees choosing not to take annual leave (and so preventing others becoming involved in their work), especially if solely responsible for a ‘risk’ area;
complaints from the public or from employees;
insistence on dealing with a particular individual

Revision of Policy

The company reserves the right to amend and/or withdraw this policy from time to time for any reason, including without limitation, to take account of changes in the law, best practice and/or operational requirements.