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. We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.
1.2 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.
2. WHO MUST COMPLY WITH THIS POLICY?
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.
ANTI-CORRUPTION AND BRIBERY
3. WHAT IS BRIBERY?
3.1 Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
3.2 Bribery includes offering, promising, giving, accepting or seeking a bribe.
3.3 All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager or Senior Management.
3.4 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;
(c) 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;
3.5 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. GIFTS AND HOSPITALITY
4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment.
4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift.
5. RECORD-KEEPING
5.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
5.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
6. HOW TO RAISE A CONCERN
If 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 report it in accordance with our Whistleblowing procedures below as soon as possible.
WHISTLEBLOWING
7. WHAT IS WHISTLEBLOWING?
Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.
8. HOW TO RAISE A CONCERN
8.1 In many cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you should contact Senior Management. Contact details are at the end of this policy.
8.2 We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.
9. CONFIDENTIALITY
Staff should feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.
10. EXTERNAL DISCLOSURES
10.1 The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In the majority of instances, you should not find it necessary to alert anyone externally.
10.2 The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We encourage you to discuss your concerns internally and seek professional advice before reporting a concern to a relevant external body.
11. PROTECTION AND SUPPORT FOR WHISTLEBLOWERS
11.1 We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken.
11.2 Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform Senior Management immediately. If the matter is not remedied you should raise it formally using our Complaints and Appeals Procedure.
11.3 You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action or potential legal proceedings brought against you by the whistleblower.
11.4 However, if we conclude that a whistleblower has made false allegations maliciously or with a view to personal gain, the whistleblower may be subject to disciplinary action.
11.5 Public Concern at Work operates a confidential helpline. Their contact details are at the end of this policy.
12. CONTACTS
Company Name: Floreo Associates Ltd
Phone: 0203 617 1137
Email: info@floreo.co.uk
Public Concern at Work
(Independent whistleblowing charity) Helpline: 0207 404 6609
Email: whistle@pcaw.co.uk
Website: www.pcaw.co.uk
