Anti bribery and corruption policy
The company will not tolerate bribery or allow improper offers or payments to or from it’s staff and employees in relation to the activities of the company. The company considers it’s reputation for ethical behaviour, it’s ability to protect client confidentiality and it’s ability to demonstrate the implement the requirements of this policy to be crucial in relation to meeting it’s clients’ requirements. The overall responsibility for ensuring the implementation of this policy is vested in the company’s Directors and Senior Managers.
Implementation of this policy is via the quality management system which ensures:
- Compliance with procedures for employment of personnel and appointment procedures for sub-contractors and relevant suppliers.
- Management of training and awareness in relation to potential for bribery and corruption and the company’s procedures to detect and prevent it, supported by Company Guidance on Ethical Behaviour and Compliance with the Anti Bribery and Corruption Policy.
- Requirements for due diligence where risk assessment indicates that it is appropriate
- Financial controls managed through the company’s financial management system and external auditors (outside of the scope of the QA system)
- Arrangements for reporting and investigating potential instances of bribery or corruption and review of performance in relation to the programme.
The company will ensure that all employees are made aware of this policy by:
- Explaining this policy to all new employees as part of the company’s formal induction procedures and documenting this.
- Displaying this policy in company offices and issuing a copy of this policy to all employees.
- Any supplier or sub-contractor whose duties and responsibilities cover activities where this policy would be relevant shall be identified by the manager authorised to appoint them and shall be issued with a copy of this policy and required to comply with it.
To support employees in their compliance with this policy, the company maintains Company Guidance on Ethical Behaviour and Compliance with the Anti Bribery and Corruption Policy.
Performance in relation to this policy is reviewed. The policy itself is reviewed by the Directors and Senior Managers in response to the findings of any investigation into any potential instance of bribery or corruption or of any significant failure to implement or comply with the Anti Corruption Programme and in relation to any relevant new legislation or published guidelines. It will also be reviewed at least annually. The new policy will be displayed and re-issued as detailed above.