Anti-Bribery Policy 

This Policy sets out the rules towards anti-corruption rules, as set out in the Bribery Act 2010 (“Bribery Act”). 

 

Scope

 

Bribery is a form of corruption which - when left unchecked - can seriously harm the economic growth of a society. In the United Kingdom as well as in many other jurisdictions both receiving and offering a bribe is a crime. 

The Bribery Act has two general offences: active bribery and passive bribery. Active bribery means either offering, receiving or giving a bribe. The definition of passive bribery consists of requesting, agreeing to receive or accepting a bribe. There is a prohibition on the bribing of a foreign public official in order to gain business advantage (section 6, Bribery Act). Firms can also become liable for a failure to prevent the use of bribery in their organisation (section 7, Bribery Act). 

The Firm should be aware of the potential legal and reputational repercussions should any of its employees, executives, or agents be found guilty of unlawful business practises such as bribery. 

As a general principle, a potential loss of business should never justify any form of bribery, large or small. The Company does not sanction bribery or any other corrupt practices under any instance.

This policy applies to all employees, partners and any agents that act on behalf of the Company, affiliated entities and partners in joint ventures (the “Policy staff”). 

Prohibition

The Company has expressly prohibited the following activities from the Policy staff:

  • offering;
  • giving;
  • soliciting; or
  • accepting

of any bribe or inducement, to or from any individual, company or entity in order to gain commercial, contractual, regulatory, or personal advantage.

The Company expects that the Policy staff will act in the same manner in accordance with the Bribery Act. The Company refuses to do business with any counterparty that fails to follow the same principles as set out in the Bribery Act.

The Company does not prohibit the following activities which do not violate the principles of the Bribery Act:

  • Normal hospitality (proportionate and reasonable to the business);
  • Ceremonial gifts;
  • Fast-tracking a process when it is available to everyone on payment of a fee; or
  • Providing resources to assist the person or body to make a decision more efficiently provided that these resources are only given for that one purpose only.

If it becomes unclear whether a particular conduct would constitute a corrupt business practice, further guidance can be sought from the Compliance Team.

Responsibilities of Policy staff

Every member of staff is responsible of preventing, detecting and reporting the acts of bribery. 

 

The prevention obligation includes, but is not limited to, the following:

  • refusing any potential or suspected bribes in an unequivocal manner;
  • promoting a culture in one’s team and larger organisation which raises awareness of commitment against corruption; and
  • acting ethically and with integrity in carrying out one’s responsibilities.

The reporting obligation includes, but is not limited to, the following:

  • reporting any offers or solicitations for bribes or other inducements;
  • reporting suspicious behavior; and
  • reporting any breaches of the Policy.

Reports of potential corrupt activities should be directed to the Compliance Officer either by phone or email depending on the urgency of the matter.

The Company has a right to take disciplinary action towards an employee who fails to follow the guidelines of this Policy. 

Management committee responsibility

 

The management committee is responsible for ensuring that this policy is up-to-date and enforced in accordance with the terms of the Policy.