Anti-Bribery

The giving, offering or receiving of any advantage including payments, gifts, loans, fees or rewards, to or from any person in order to influence them corruptly or improperly.

Involves, but isn't limited to:

• extortion

• fraud

• deception

• collusion

• abuse of entrusted power or position

• embezzlement

• money laundering for private gain

We may investigate:

• requests for cash payments

• requests for payments to be made offshore

• demands for payment at short notice

• absence of documentation to support payments

• prevalence of bribery in a certain country

• lack of written agreements

• unusually close relationships with government officials

• payment of large success fees

Genuine hospitality and promotional spend is a legitimate part of doing business, but we have to ensure any hospitality, promotional or other business spend can't be considered a bribe. We'll allow reasonable and appropriate hospitality or entertainment if its for the purpose of:

• establishing and maintaining good business relationships

• improving or maintaining our image or reputation

• marketing or presenting or services effectively

You can give or receive gifts provided they are:

• not done with the intention of influencing someone

• done in our name, not yours

• not cash (or vouchers)

• appropriate to the circumstances (for example small gifts at Christmas)

• given openly, never in secret

• complicit with any local laws

We can't allow you (or someone on your behalf) to:

• give promise or offer payments, gifts or hospitality to gain advantage, or to reward advantage already given

• accept payments, gifts or hospitality knowing or suspecting it's done with the expectation of an advantage

• accept hospitality that is repeated, unduly lavish or extravagant

• offer or accept gifts to or from government officials, politicians or political parties

• threaten or retaliate against anyone who has refused to commit a bribery offence or who raises a concern

• engage in other activity that may breach our anti-bribery and corruption stance

We wouldn't normally consider the following to be hospitality:

• working lunches or refreshments provided during a business visit

• hospitality given to anyone attending a seminar, conference or other business event (as long as its given to everyone in attendance)

• free seminars, workshops and talks (as long as they're free for all)

Corporate hospitality would be any other form of accommodation, entertainment or hospitality provided for or by you.

Please speak to your manager if you receive, or want to give, a gift of more than £20 in value. Receiving tokens such as promotional pens, calendars and stationery are acceptable.

If you feel that refusing a gift would cause embarrassment to the giver, you can accept the gift and donate it to a charity of our choosing, please let your manager know if this happens. If you are in any doubt whether a gift or hospitality is improper, you should decline.

Sometimes charitable donations can still be seen as influential - for example if you make a charitable donation to a charity sponsored by a customer, it could be seen as attempting to influence that customer.

Even if there's no intent, it could still create reputational damage to us, so we generally don't make charitable donations unless:

• they're to recognised non-profit organisations

• they're transparent and properly recorded in our accounts

• a receipt or letter of acknowledgement is given to evidence payment

If you get asked about company donations to charity, please refer this to your manager.

We don't make political donations of any kind. We respect your right to make personal donations to political parties, but we'll never directly or indirectly reimburse you for this.

Political lobbying can be legitimate, but can also attract unfavourable publicity. You aren't permitted to take part in political lobbying on our behalf without written approval from the directors.

Small, unofficial payments made to speed up or ensure the performance of routine or necessary actions. Under the UK Bribery Act 2010, these payments are unlawful and a never permitted by us.

Please raise your concerns to your manager, or your area manager as soon as possible. If you feel you can't do this, please speak to HR or use our Confidential Reporting process.