It is the policy of RW Sadlers Ltd and Auker Rhodes Accounting Limited to conduct business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. We have implemented and enforce effective systems to counter bribery and corruption.
We uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we conduct business: specifically, in the United Kingdom, the Bribery Act 2010 (“the Act”), which applies to conduct both here and abroad.
This policy applies to all individuals working for or on our behalf at all levels, whatever their employment status and wherever located.
In this policy, a third party means any individual or organisation that we come into contact with during the course of work and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies, politicians and political parties.
What is bribery?
A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage. Under the Act it is an offence to:
- give or offer a bribe;
- receive or request a bribe; or
- bribe a foreign public official.
We may also be liable under the Act if we fail to prevent bribery by an associated person for our benefit.
Gifts and hospitality
This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from a third party. However, we have specific internal policies which provide guidance to our workers as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below. Any gift or hospitality:
- must not be made with the intention of improperly influencing a third party or worker to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
- must comply with local law in all relevant countries;
- must be given in the name of the organisation, not in an individual’s name;
- must not include cash or a cash equivalent;
- must be appropriate in the circumstances;
- must be of an appropriate type and value and given at an appropriate time considering the reason for the gift;
- must be given openly, not secretly; and
- in the case of gifts, they must not be offered to, or accepted from, government officials or representatives, politicians or political parties.
What is not acceptable?
It is not acceptable for any worker (or someone on their behalf) to:
- give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or we will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
- give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;
- accept payment from a third party where it is known or suspected that it is offered or given with the expectation that the third party will improperly obtain a business advantage;
- accept a gift or hospitality from a third party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by us in return;
- threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
- engage in any activity that might lead to a breach of this policy.
We do not make, and will not accept, facilitation payments of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.
Charitable donations and sponsorship
We only make charitable donations and provide sponsorship that is legal and ethical under local laws and practices and which are in accordance with our internal policies.
We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.
Responsibilities and raising concerns
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy
Workers are required to notify us as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.
Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee workers if they breach this policy.
If any third party is aware of any activity by any worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with us in writing to Rob Sadler.
Training and communication
Training on this policy is provided for all workers and our zero tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors and business partners.
Monitoring and review
We monitor the effectiveness and review the implementation of this policy at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to provide assurance that they are effective in countering any risks of bribery and corruption.