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Redego Anti-Bribery and Corruption Policy

1. Introduction

The Bribery Act 2010 came into force on the 1st of July 2011, replacing a number of older laws and creating a single comprehensive code in relation to Bribery and Corruption. The Act creates new offences and places responsibility on organisations as well as the individual. The Act also covers the acts of agents or associates acting on behalf of the organisation. The penalties are severe with potentially unlimited fines and the possibility of imprisonment up to a maximum of ten years for individuals.

The Act creates four offences. The first three are offences that are committed by individuals and the fourth is a corporate offence:

  1. Promising or offering a bribe;
  2. Requesting, agreeing to receive or accepting a bribe;
  3. Bribing a foreign public official;
  4. A corporate offence of ‘failure to prevent bribery’ by ‘persons associated’ with an organisation.

What is bribery?

In its Guide to the Bribery Act. the Ministry of Justice says:

‘Very generally, [bribery] is defined as giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so.’

What is ‘bribing another person’?

The offering, promising or giving of a reward to induce a person to perform a relevant function or activity improperly. For this offence to be committed there needs to be evidence that the act under consideration was carried out with the purpose of inducing a person to act improperly. The government guidance gives examples of situations.

What is ‘being bribed’?

The accepting of, agreeing to accept or requesting of a reward in return for performing a relevant function or activity improperly.

2. Scope of Policy

The purpose of this policy is to:

  • set out our responsibilities, and the responsibilities of those working for us, in observing and upholding our position on bribery and corruption; and
  • provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.
  • If we are found to have taken part in corruption, we could face an unlimited fine, and face damage to our reputation. We therefore take our legal responsibilities very seriously.
    In this policy, third party means any individual or organisation that comes into contact with any worker or employee of the Company during the course of their work, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

    It is not the intention of the Policy to prevent the following activities:

  • normal and appropriate hospitality
  • the giving and receiving of modest gifts
  • Such hospitality or gifts must be proportionate, reasonable and made in good faith and not place any expectation on the recipient to reciprocate either in like or by performing, or failing to perform, any other task in return.

    The Company is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. This Policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. The Company does not tolerate any form of bribery, whether direct or indirect, by, or of, its employees, governors, temporary workers, consultants, contractors, agents and subsidiaries or any persons or body acting for it or on its behalf.

    Senior management is committed to implementing effective measures to prevent, monitor and eliminate bribery.

    3. Who does the Policy apply to?

    This Policy applies to all employees of the Company, and to ‘associated persons’, which includes temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, the Company. Every employee and associated person acting for, or on behalf of, the Company is responsible for maintaining the highest standards of business conduct.

    All employees and associated persons are required to comply with this Policy, in accordance with the Bribery Act 2010.

    4 Preventing and reporting bribery

    All Company employees and associated persons have a responsibility to prevent, detect and report bribery. Individuals are encouraged to raise concerns about any instance or suspicion of malpractice at the earliest possible stage. Any employee who breaches this Policy will face disciplinary action. We reserve our right to terminate our contractual relationship with associated persons if they breach this Policy.

    It is the responsibility of all employees/workers:

  • To read, understand and comply with this Policy.
  • To notify the Managing Director as soon as possible if a conflict with this Policy has occurred, or may occur in the future.
  • The Company is committed to ensuring no one experiences any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.

    5. Rewards

    Providing “rewards”

    We do not offer any referral fees, rewards, incentives, vouchers or any other thing of monetary value to agencies, end-clients, or their staff or associates in return for new business or to maintain existing business.

    We may, from time to time, and at our discretion, offer a reward to existing employees where a recommendation results in new business.

    Accepting “rewards”

    Workers, associates or employees of the Company must not accept anything of monetary value from a client, agency or individual where there is an expectation that the acceptance will facilitate “improper” behaviour to the advantage of the client, agency or individual.

    Requesting “rewards”

    We will not, nor any persons associated with the Company, request a “reward” from a third party, nor behave “improperly” to the advantage of a third party.

    6. Training and Communication

    Training on this policy forms part of the induction process for all new workers. All existing workers will receive relevant training on how to implement and adhere to this policy.

    Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

    Who is responsible for the Policy?

    The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

    The HR Director has primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation.

    Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.

    8. Monitoring and review

    The HR Director will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

    All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

    This policy does not form part of any employee’s contract of employment and it may be amended at any time.