Anti Bribery/Corruption Policy
One of the Company’s core values is to uphold responsible and fair business practice. It is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business activities. Its reputation for maintaining lawful business practices is of paramount importance and this Policy is designed to preserve these values. The Company therefore has a zero tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings and relationships and to implementing and enforcing effective systems to counter bribery.
2. Purpose and scope of this policy
This Policy sets out the steps all of us must take to prevent bribery and corruption in our business and
to comply with relevant legislation. It is aimed at:
ensuring compliance with anti-bribery laws, rules and regulations, not just within the UK but in
any other country within which the Company may carry out its business or in relation to which
its business may be connected;
enabling any Relevant Person to understand the risks associated with bribery and to encourage
them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether by
themselves or others;
providing suitable and secure reporting and communication channels and ensuring that any
information that is reported by the healthcare workers is properly and effectively dealt with;
creating and maintaining a rigorous and effective framework for dealing with any suspected
instances of bribery or corruption.
All Relevant Persons are expected to adhere to the principles set out in this Policy.
3. The Bribery Act 2010
The Bribery Act 2010 (the Bribery Act) came into force on 1 July 2011. The Bribery Act affects the
Company in its business relations anywhere in the world.
Under the Bribery Act it is an offence to:
a. bribe a person i.e. to offer, promise or give a financial or other advantage to another person,
whether within the UK or abroad, with the intention of inducing or rewarding improper conduct;
b. receive a Bribe i.e. to request, agree to receive or accept a financial or other advantage for or in
relation to improper conduct;
c. bribe a foreign public official; and
d. fail to prevent Bribery.
4. Risks of not acting with integrity.
Involvement in Bribery or corruption carries many risks. Among them are:
a company which pays or accepts Bribes is not in control of its business and is at risk of blackmail;
if the Company is found guilty of Bribery or even of failing to have adequate procedures in place
to prevent Bribery, it will be subject to unlimited fines;
any person found guilty of Bribery will be subject to fines and/or imprisonment of up to 10 years;
a public exposure, or even allegation, of bribery would entail severe reputational damage. The
Company’s banking or supply facilities might be withdrawn or be available on much less
favourable terms, and the Company could be blacklisted as an approved tenderer for both public
and private sector contracts;
the cost of our insurance cover could increase very significantly; and
good people will not want to work for us.
5. Benefits of acting with integrity
Equally, there are very clear benefits to acting with propriety. These include:
we increase our chances of being selected as a supplier in both the public and private sectors;
we remain in good standing with our banks and our own suppliers and they will want to keep
doing business with us;
a business with high ethical standards is a good place to work; and
it is a requirement of the REC Code of Professional Practice that we act with integrity at all times.
6. Policy statement
All Relevant Persons and Associated Persons are required at all times:
not to commit an offence listed above at section 4 or any other offence;
to comply with the Bribery Act and any other anti-bribery and anti-corruption legislation that
applies in any jurisdiction in any part of the world in which they or the Company might conduct
to act honestly, responsibly and with integrity;
to safeguard and uphold the Company’s core values by operating in an ethical, professional
and lawful manner at all times.
Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made,
money set aside or accounts created for the purposes of facilitating the payment or receipt of a Bribe.
The Company recognises that industry practices may vary from country to country or from culture to
culture. What is considered unacceptable in one place may be normal or usual practice in another. You
should seek appropriate guidance from the Company’s Compliance Officer. All Relevant Persons and
all Associated Persons are expected to adhere strictly at all times to the guidelines set out in
this Policy. If you are in doubt as to what might amount to bribery or what might constitute a breach
of this Policy, refer the matter to the Company’s Compliance Officer.
7. Gifts and Hospitality
The Company occasionally provides gifts and hospitality to clients, customers, contractors, and
suppliers. This is not prohibited by the Bribery Act provided the following requirements are met:
the gift is not made with the intention of influencing a third party to obtain or retain business or a
business advantage, or to reward the provision or retention of business or a business
it complies with local laws;
it is given in the Company’s name, not in the giver’s personal name;
it does not include cash or a cash equivalent (such as gift vouchers);
it is of an appropriate and reasonable type and value and given at an appropriate time;
it is given openly, not secretly;
it is approved in advance by a director of the Company.
In summary, it is not acceptable to give, promise to give, or offer, a payment, gift or hospitality with the
expectation or hope that a business advantage will be received, or to reward a business advantage
already given, or to accept a payment, gift or hospitality from a third party that you know or suspect is
offered or provided with the expectation that it will obtain a business advantage for them.
8. Facilitation payments
Any payment or gift to a public official or other person to secure or accelerate the prompt or proper
performance of a routine government procedure or process, otherwise known as a “facilitation
payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are
common in some other jurisdictions.
10. What are the indicators of bribery?
Common indicators of corruption include those listed below. There may well be others. For example:
• payments are for abnormal amounts (e.g. commission), or made in an unusual way, e.g. what
would normally be a single payment is made in stages, through a bank account never previously
used, or in a currency or via a country which has no connection with the transaction;
• process is bypassed for approval or sign-off of terms or submission of tender documents,
payments, or other commercial matters; those whose job it is to monitor commercial processes
(e.g. [insert person or department specific to Company, e.g. Internal Audit]) may be prevented
from or hindered in doing so;
• individuals are secretive about certain matters or relationships and/or insist on dealing with them
personally. They may make trips at short notice without explanation, or have a more lavish
lifestyle than expected;
• decisions are taken for which there is no clear rationale;
• records are incomplete or missing.
10. Political contributions
You should be aware that such contributions can be (or be seen as) Bribes in disguise. We do not make
donations to political parties. No individual is to make a donation stated to be, or which could be taken
to be, on our behalf without the prior approval of the Board. You may, of course, make political donations
in a personal capacity but please be sensitive to how such contributions could be perceived, especially
by those who are aware of your connection with the Company.
11. Charitable donations
Bribes may even be disguised as charitable donations. Again, for that reason, donations we make are
approved by resolution of the Board and recorded. Whilst individuals may of course make personal
donations to charity, they should not do so on behalf of the Company without prior approval from the
12. Local circumstances
We understand that different parts of the world have different social and cultural customs. This does
not affect our position that we do not pay or accept bribes or act corruptly: we do not and will not.
However, subject to that position, we understand the need to be sensitive to local customs. For
example, there are cultures in which refusing (or even failing to offer) a gift is considered impolite, and
could alienate a key contact. In such cases, please refer to the Directors. Heads of business units are
responsible for establishing variations to this Policy in their unit subject to the agreement of the Human
Resources Director and the Chief Counsel.
13. Exceptional circumstances
In some circumstances a payment is justifiable. If one of our people is faced with a threat to his or her
personal safety or that of another person if a payment is not made, they should pay it without fear of
recrimination. In such cases, however, chief counsel must be contacted as soon as possible, and the
payment and the circumstances in which it was made must be fully documented and reported to the
Human Resources Director for the business concerned within five working days. Consider carefully
whether to involve the police. There may be cases where this will actually make the situation worse. If,
on consideration, this appears to be the best course of action, always consult the Legal Department
Such cases will be rare. All Relevant Persons visiting regions where they are more common should
familiarise themselves, prior to travel, with current guidance relating to those countries. The Human
Resources Department should be consulted if in doubt. For general information on travelling to a
particular country, please consult the latest information from the Foreign and Commonwealth Office.
14. Responsibility to report and the reporting procedure
All Relevant Persons are contractually required to take whatever reasonable steps are necessary to
ensure compliance with this Policy and to prevent, detect and report any suspected Bribery or
corruption. All Relevant Persons have a duty to prevent, detect and report any incident of Bribery and
any potential risks of Bribery. If you know or suspect that any Relevant Person plans to offer, promise
or give a Bribe or to request, agree to receive or accept a Bribe in connection with the Company’s
business, you must disclose this to the Company’s Compliance Officer as quickly as possible to allow
appropriate action to be taken promptly.
The Company is committed to taking appropriate action against Bribery and corruption. This may
include either reporting the matter to an appropriate external government department, regulatory
agency or the police and/or taking internal disciplinary action against relevant employees and/or
terminating contracts with associated persons.
The Company will keep your disclosure confidential during any investigation it undertakes to the extent
that this is practical and appropriate in the circumstances. The Company will support anyone who raises
genuine concerns in good faith under this Policy, even if they turn out to be mistaken. The Company is
also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part
in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential
bribery or corruption offence has taken place or may take place in the future or because they may assist
in the investigation of an allegation of Bribery or corruption.
15. Record keeping
All accounts, receipts, invoices and other documents and records relating to dealings with third parties
must be prepared and maintained with strict accuracy and completeness. No accounts must be kept
“off the record” to facilitate or conceal improper payments.
16. Monitoring compliance
The Company’s Compliance Officer has primary responsibility for ensuring compliance with this Policy
and will review its contents on a regular basis. S/he will be responsible for monitoring its effectiveness
and will provide regular reports in this regard to the directors of the Company who have overall
responsibility for ensuring this Policy complies with the Company’s legal and ethical obligations.
The Company will provide training to all employees to help them understand their duties and
responsibilities under this Policy. The Company’s zero tolerance approach to Bribery will also be
communicated to all business partners at the outset of the business relationship with them and as
18. Sanctions for breach of this Policy
A breach of any of the provisions of this Policy by any Relevant Person who is an officer or employee
of the Company will constitute a disciplinary offence and will be dealt with in accordance with the
Company’s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross
misconduct and could render the officer or employee liable to summary dismissal.
Breach of this policy by any Relevant Person who is a temporary worker, contractor or consultant
providing his/ her services to the Company may lead to the immediate termination of that temporary
workers, contractor’s or consultant’s engagement by the Company.
Breach of this policy by any Relevant Person which is a corporate entity could lead to the suspension
or termination of any relevant contract, sub-contract or other agreement between the corporate entity
and the Company. to ensure legality of personal data handling and processing activities
Winifred B Kagere,