Policy contents
1Purpose and Scope
This Anti-Bribery and Corruption Policy sets out the responsibilities of Albrighton Group Services Ltd and everyone working for or on behalf of the company in observing and upholding our zero-tolerance position on bribery and corruption.
It also provides information and practical guidance to help individuals recognise, prevent and report bribery and corruption risks and understand their personal responsibilities.
2Policy Statement
Albrighton Group Services Ltd is committed to conducting business ethically, honestly and with integrity. We implement and maintain proportionate systems and controls designed to prevent bribery and corrupt activity.
We comply with applicable anti-bribery and corruption laws in the jurisdictions in which we operate, including the Bribery Act 2010 in relation to conduct in the United Kingdom and overseas.
Bribery offences can result in serious criminal, financial, procurement and reputational consequences. The company therefore takes its legal and ethical responsibilities seriously.
Official sources: Read the Bribery Act 2010 and the Ministry of Justice's Bribery Act 2010 guidance for commercial organisations. The guidance sets out six principles for bribery prevention: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.
3Who Is Covered by This Policy?
This policy applies to all employees, whether temporary, fixed-term or permanent, and to consultants, contractors, trainees, seconded staff, home workers, casual workers, agency workers, volunteers, interns, agents, sponsors and other persons associated with Albrighton Group Services Ltd.
It also applies to directors, officers, managers and relevant third parties, including actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, government bodies and public bodies.
Arrangements with third parties should be supported by clear contractual terms and proportionate anti-bribery and corruption requirements.
4Definition of Bribery
Bribery includes offering, promising, giving, requesting, agreeing to receive or accepting a financial or other advantage with the intention of inducing or rewarding improper conduct.
A bribe may be money, a gift, hospitality, a favour, an opportunity, an improper discount or any other advantage intended to obtain a commercial, contractual, regulatory or personal benefit.
Employees and associated persons must not:
- offer, promise or give a bribe;
- request, agree to receive or accept a bribe;
- bribe a foreign public official;
- use an agent, supplier or other third party to make an improper payment; or
- ignore circumstances that create a clear bribery or corruption risk.
5What Is and Is Not Acceptable
5.1Gifts and Hospitality
Reasonable and proportionate business hospitality or goodwill gestures may be permitted where they are transparent, lawful and not intended to influence a decision improperly.
Gifts and hospitality must:
- not be intended to obtain or reward an improper business advantage;
- not be offered or accepted in expectation of a return favour;
- comply with applicable law and company procedures;
- be given in the company's name rather than an individual's name;
- not comprise cash or a cash equivalent;
- be appropriate in type, value, timing and frequency;
- be given and received openly rather than secretly;
- not be targeted at an influential individual to affect a decision;
- be declared and recorded where required; and
- receive prior approval where the value exceeds the company's permitted threshold, normally £100, or where a public official, politician or political party is involved.
Where declining a gift may cause genuine cultural offence, it may be accepted only where it is promptly declared and reviewed by the compliance manager.
5.2Facilitation Payments and Kickbacks
Albrighton Group Services Ltd prohibits facilitation payments and kickbacks. These are forms of bribery and must not be offered, made, requested or accepted.
Where an employee reasonably believes that refusing a payment creates an immediate threat to personal safety, they should prioritise safety, keep any payment to the minimum, request a receipt where practicable, record the circumstances and report the matter immediately.
5.3Political Contributions
The company does not make donations in cash, kind or through other means to support political parties or political candidates where the contribution could be perceived as seeking an improper business advantage.
5.4Charitable Contributions
Albrighton Group Services Ltd supports lawful and ethical charitable activity. Contributions must be transparent, appropriately approved and must never be used to conceal bribery or obtain an improper advantage.
6Employee Responsibilities
Employees and associated persons must read, understand and comply with this policy and with relevant anti-bribery and corruption training.
Everyone under the company's control is responsible for preventing, detecting and reporting bribery and corruption and must avoid activity that could breach, or appear to breach, this policy.
Suspected or actual bribery must be reported promptly. Breaches may result in disciplinary action, dismissal for gross misconduct or termination of a commercial or contractual relationship.
7Raising Concerns and Protection
Anyone who suspects bribery or corrupt activity connected with Albrighton Group Services Ltd should raise the concern at the earliest reasonable opportunity with their line manager, compliance manager, a director or the appropriate governance contact.
Anyone offered a bribe, asked to make a bribe, or who believes they are the victim of corrupt activity must report the matter promptly.
The company supports individuals who raise genuine concerns in good faith, even where an investigation concludes that they were mistaken. Retaliation, dismissal, disciplinary action, threats or other detrimental treatment for raising a genuine concern is prohibited.
8Training and Communication
Anti-bribery and corruption training is included in appropriate induction and refresher arrangements. Higher-risk personnel may receive additional role-specific training.
The company's zero-tolerance approach will be communicated to relevant suppliers, contractors, business partners and other third parties at the beginning of the relationship and where appropriate thereafter.
9Record Keeping
Albrighton Group Services Ltd will maintain accurate financial records and appropriate internal controls supporting payments, expenses, gifts, hospitality, charitable contributions and other relevant transactions.
Records must accurately describe the purpose and value of a transaction and must not be falsified, misleading, incomplete or concealed.
10Monitoring and Review
The compliance manager is responsible for monitoring the implementation and effectiveness of this policy and reviewing its suitability, adequacy and operation regularly.
Internal controls and procedures designed to prevent bribery and corruption may be audited and improved in response to identified risks, incidents, legal developments and employee feedback.
This policy does not form part of an employee's contract of employment and may be amended where necessary to improve its effectiveness.