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Category: Associated Policies 010
Last updated: 03/09/2024 by Danni Fraser-pickard
Approved by:
- ANTI-BRIBERY POLICY
Table of contents
Anti-Bribery |
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RK Bell Group - 10596233 - Trading as RK Bell Ltd 00587692 - RK Bell Projects Ltd 06637268- Gworks Surfacing Ltd 10596233
ANTI-BRIBERY POLICY
Policy Statement
For the purpose of this policy, The RK Bell Group, also known as RK Bell, incorporates RK Bell Ltd, RK Bell Projects Ltd, and Gworks Surfacing Ltd.
The Bribery Act 2010 came into force in July 2011 with the principal aim of preventing acts of bribery within organisations. This policy addresses important bribery-related matters, including gifts and hospitality, payments to officials, and political and charitable donations.
Definition
Bribery is, in the conduct of the Company's business, the offering or accepting of any gift, loan, payment, reward, or advantage for personal gain as an encouragement to do something dishonest, illegal, or a breach of trust.
Bribery is a criminal offence. The Company prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us, and we have a zero-tolerance attitude towards corrupt activities of any kind, whether committed by RK Bell employees at all levels, agency workers, contractors, or suppliers.
Purpose
The purpose of this policy is to convey to all employees and interested parties of RK Bell the rules of the Company in relation to our unequivocal stance towards the eradication of bribery and our commitment to ensuring that we, as a Company, conduct our business in a fair, professional, and legal manner.
Offences
It is a criminal offence to:
- Offer a bribe
- Accept a bribe
- Bribe a foreign official
- As a commercial organisation, to fail to prevent a bribe.
You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. The Company could also face prosecution and be liable to pay a fine.
Definitions of Bribery and Corruption
Corruption is the misuse of office or power for private gain. Bribery is a form of corruption which means, in the course of business:
- Giving or receiving money, gifts, meals, entertainment, or anything else of value.
- As an inducement to a person to do something dishonest or illegal.
Scope
This policy applies to all employees of the Company, regardless of seniority or site. It also extends to anyone working for or on our behalf, e.g. those engaged by us on a self-employed basis or an agency arrangement.
We will encourage the application of this policy where our business involves the use of third parties, e.g. suppliers, contractors.
Policy
It is prohibited, directly or indirectly, to offer, give, request, or accept any bribe, i.e. gift, loan, payment, reward, or advantage, either in cash or any other form of inducement, to or from any person or company to gain commercial, contractual, or regulatory advantage for the Company, or to gain any personal advantage for an individual or anyone connected with the individual in an unethical way.
It is also prohibited to act in the above manner to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.
If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact a Director of the Company so that action can be taken if considered necessary. You may be asked to give a written account of events.
If you, as an employee or person working on our behalf, suspect that an act of bribery or attempted bribery has taken place, even if you are not personally involved, you are expected to report this to a Director of the Company. You may be asked to give a written account of events.
Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.
The Company will ensure that all of its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.
The Company takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.
We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery or attempted bribery has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, an agency worker, a contractor, etc.
Gifts and Hospitality
We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery, and consequently, such actions are not considered a breach of this policy.
Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans given or received as a mark of friendship or appreciation.
Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present.
No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from a Director. Similarly, no gift nor offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from a Director.
A record will be made of every instance in which gifts or hospitality are given or received.
As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.
Competition Law
RK Bell is a firm supporter of the free market economy. As such, we are fully committed to compliance with the national and international requirements of competition law by our group of companies as an essential tool for ensuring fair, unrestricted competition.
Violation of the competition laws can have dramatic consequences for the group, its directors, and its staff. We could face a variety of negative repercussions, including serious fines, lawsuits, exclusion from public contracts, and serious harm to our reputation.
Individuals who agree with others to violate competition laws also face severe external repercussions, including possible imprisonment, heavy fines, and, in the case of directors, disqualification. RK Bell will not show any leniency towards employees or directors who disregard competition laws. If an employee or director becomes aware of conduct within or outside the firm that appears to involve a risk of secret cooperation with a competitor, it is essential that it is brought to the attention of a director immediately to enable appropriate steps to be taken to bring an infringement to an end or, where possible, to avoid such an infringement.
The viability and effectiveness of this policy will be regularly reviewed. Constant monitoring along with frequent evaluation and reporting are designed to ensure continual improvement.
Further guidance has been provided to businesses by the Competition and Markets Authority (CMA) on their website. The CMA is the body responsible for the enforcement of the competition rules in the UK, with wide powers of investigation and enforcement in relation to all issues.
Reviewed: 03/09/2024
v1.2.4
Approved by: