![]() ![]() It may also be an offence for the potential client to accept your offer. We may also be found to have committed an offence because the offer has been made to obtain business for us. This would be an offence as you are making the offer to gain a commercial and contractual advantage. Offering a bribe: You offer a potential client ticket to a major sporting event, but only if they Individuals found guilty can be punished by up to ten years’ imprisonment and/or a fine and employers that fail to prevent bribery can face an unlimited fine, exclusion from tendering for public contracts, and damage to its reputation.ĥ.2 Corruption is the abuse of entrusted power or position for private gain. It is a criminal offence to offer, promise, give, request, or accept a bribe. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind. (b) A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. (a) An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value. ![]() ![]() Definitionsĥ.1 Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage. They will involve the Group General Counsel where appropriate.Ĥ.3 This policy is reviewed continually by the Group General Counsel in consultation with the Board. Suggestions for change should be reported to Group General Counsel.Ĥ.2 The HR Department has day-to-day responsibility for this policy, and you should refer any questions about this policy to them in the first instance. Who is responsible for the policy?Ĥ.1 The board of directors (the Board) has overall responsibility for the effective operation of this policy but has delegated responsibility for overseeing its implementation to Group General Counsel. This policy applies to all persons working for us or any group company 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, sponsors, or any other person associated with us, wherever located. (b) provide information and guidance to those working for and on our behalf on how to recognise and deal with bribery and corruption issues.Ģ.2 This policy has been agreed with the Board.Ģ.3 This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time following consultation with the Board and Group General Counsel. (a) set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on bribery and corruption and However, we remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. 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 wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.ġ.2 We take our legal responsibilities very seriously. ![]() 1.1 We conduct all our business in an honest and ethical manner. ![]()
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