Purpose
All Invicta Building Services Limited personnel are expected to conduct company business in a legal and ethical manner. Invicta Building Services Limited should not use illegal payments, bribes, kickbacks or other questionable inducements to influence government policy or any business transaction. The use of Invicta Building Services Limited funds or assets for any unlawful, improper or unethical purpose is prohibited. In the conduct of business, all employees must avoid making payments that may be or may be perceived to be improper. Specifically, Invicta Building Services Limited prohibits bribery by any of its employees or agents.
Scope
Responsibilities
Introduction
- Setting out a clear anti-bribery policy.
- Encouraging its employees to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately.
- Requiring all employees to act honestly and with integrity at all times and to safeguard the Company resources for which they are responsible.
- Ensuring transactions are properly and accurately recorded.
- Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution.
- Taking firm and vigorous action against any individual(s) involved in bribery.
The Policy
the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement
to or from
any person or company, wherever they are situated and whether they are a public official or body or private person or company
by
any individual employee, agent or other person or body acting on Invicta Building Services Limited’s behalf
in order to
gain any commercial, contractual or regulatory advantage for Invicta Building Services Limited a way which is unethical
or in order to
gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual
Further Clarification
This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:
- normal and appropriate hospitality
- the giving of a ceremonial gift on a festival or at another special time
Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the Company Secretary or a Director before proceeding.
Employee Responsibility
Training and communications
We will communicate this policy and relevant guidance to employees within Invicta Building Services Limited through our established internal communication channels. We will also communicate this policy to our suppliers, contractors and business partners and wider stakeholders.
Raising concerns and seeking guidance
Monitoring and review
Key Legislation
- UK Fraud Act 2006
- Bribery Act 2010
- UK Anti-Terrorism, Crime & Security Act 2001
- UK Corporate Governance Code (2010)
- UK Money Laundering Regulations 2007
- UN Convention Against Corruption (2003)
- Convention on Combating Bribery of Foreign Public Officials in International
- Business Transactions (OECD)
- Council of Europe Criminal Law Convention on Corruption (1998) and
- additional Protocol (2005)
Definitions
Corruption: Illegal, immoral or dishonest behaviour.
Bribe: to ask or make someone do something for you, in return for payment (for example, but not limited to) payment, gifts, money or favours.
This policy has been endorsed by Nick Gallagher, Managing Director and has the full support of the company’s senior management team. It is reviewed at least annually and updated, if necessary, following consultation with the company’s employment law consultants.