1. About this policy
1.1 It is our policy to conduct 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.
1.2 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. This policy does not form part of any employee’s contract of employment and we may amend it at any time. It will be reviewed regularly, at least annually.
2. Who must comply with this policy?
2.1 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.
3. Bribery
3.1 All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager or your HR
3.2 Specifically, you must not:
(a) 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;
(b) 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;
3.2 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.
3.3 You must not 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.
4. What steps do I take when receiving gifts or hospitality?
4.1 Promotional gifts of low value (below £75) such as branded stationery, umbrellas etc. may be accepted from existing customers, suppliers and business partners. No other types of gift may be accepted under this policy – they should be returned to the third party with an explanation to the effect that it is not our policy to accept gifts.
4.2This policy does not prohibit the accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
4.3Hospitality 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).
4.4You should not purchase goods or services for yourself or your family from a supplier without the prior written approval of your managing or site director.
4.5When considering whether to accept or decline hospitality, please use the table below and ensure the correct procedure is followed:
| Benefit received | Procedure |
| Attendance at business functions associated with your role or your professional status (that is, professional lunches, dinners or professional events). | Obtain prior written approval from your Manager and record the attendance with your HR manager. |
| If from an existing supplier – Attendance at purely social events (such as sporting events, horse racing, golf days) | Obtain prior written approval from your Manager and record the attendance with your HR manager. |
| If from a potential supplier – Attendance at purely social events (such as sporting events, horse racing, golf days) | Such hospitality cannot be accepted under any circumstances. |
5. What steps do I take when giving gifts or hospitality?
5.1In general, gifts should not be given to clients, potential clients or third parties. The exceptions to this rule are branded products (for example, pens and stationery), modest refreshment and hospitality and celebrations (for example, on the conclusion of a project). If you are in doubt as to whether a gift or hospitality should be given, please seek advice from your Manager.
5.2It is essential that the following steps are taken when giving gifts or hospitality:
(a) Gifts or hospitality given must be pre-approved by your Manager.
(b) Benefits provided with a value exceeding £75 in total must be recorded with details of the individual or customer to whom it was provided.
(c) Gifts and hospitability given must be consistent with the policy of the applicable third party organisation.
6. How to raise a concern
6.1If 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 the HR, or report it in accordance with our Whistleblowing Policy as soon as possible. If you need any further advice on sections 4 or 5 above, please contact your HR team.
December 2022