The purpose of this document is help the company carry out its business in an ethical manner and specifically to comply with the requirements of the Bribery Act 2010 by setting out a clear anti-bribery policy. To achieve this:-
This policy covers all directors, employees and agents of the company and anyone else who may, from time to time, represent the company with the knowledge and permission of its directors.
The company prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company by any individual employee, board member, agent or other person or body acting on the company’s behalf in order to gain any commercial, contractual or regulatory advantage for the company in a way which is unethical or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
The company will carry out a risk assessment for bribery and corruption that will enable procedures and training to be put in place so that compliance with the objectives of this policy can be demonstrated and met.
The Bribery Act 2010 makes provision for individual and corporate responsibility with imprisonment for up to 10 years and unlimited fines depending upon the nature of the offence for individuals and corporate fines that may be unlimited. All employees will be subject to our disciplinary procedures which could result in dismissal. There is also the possibility that criminal and or civil legal action will be taken. Those acting in a business relationship (including Agents, Suppliers and Contractors) with the company will have their business relationship terminated, the matter will be reported to the appropriate authorities and there is the possibility of criminal and or civil legal action.
M C Naylor,