Anti-Bribery & Corruption Policy
Introduction
Unique Van Bodies values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. It is important to the long term success of the company that it maintains and protects its reputation for integrity and honesty in all areas of its business dealings and that it complies with all relevant laws and regulations.
This policy applies strictly to all directors, officers and employees of Unique Van Bodies and all are expected to be familiar with this and any other such policies. The company also expects those with whom it does business to have similar standards and values. It applies within all regions, areas and functions.
The Bribery Act 2010
The Bribery Act 2010 came into force on 1st July 2011. It sets out the offences of:
- bribing another person;
- requesting, agreeing to receive, or accepting a bribe from another person;
- bribing a foreign public official;
- commercial organisations failing to prevent bribery.
Bribery can be defined as offering, promising or giving a financial (or other) advantage to another person with the intention of inducing or rewarding that person to act or for having acted in a way which a reasonable person would consider improper in the circumstances. Corruption is any form of abuse of entrusted power for private gain and may include, but is not limited to, bribery.
Bribes are not always a matter of handing over cash. Gifts, hospitality and entertainment can be bribes if they are intended to influence a decision.
Under the Act, bribery by individuals is punishable by up to 10 years’ imprisonment and/or unlimited fine. If Unique Van Bodies is found to have taken
who will be acting on the Company’s behalf. This can include agents, contractors, consultants etc. Third parties should only be engaged where there is a clear business rationale for doing so, with an appropriate contract. Any payments to third parties should be properly authorised and recorded.
Conflicts of Interest
Employees must avoid conflicts of interest between their activities outside Unique Van Bodies and their responsibilities within the Company. This could include favouring families or friends in business dealings, or dealing with a company that is owed by relatives.
Political & Charitable Donations
All employees have a right to their own political views. The use, however, by individual employees of Unique Van Bodies’ funds or resources for political purposes is strictly forbidden.
Donations to charities may be misconstrued in certain circumstances so the use of Unique Van Bodies’ funds for charitable donations must be approved by the Managing Director or Company Secretary.
Competition
Unique Van Bodies is subject to competition law in all aspects of its operations. The rules not only apply to us but also to our competitors, suppliers and customers. Employees must be aware of these laws and the activities that infringe them, such as agreements to fix prices or agreements with competitors or customers, or not to bid for business from certain companies or in certain geographical areas.
Record Keeping
Record keeping can be exploited to conceal bribes or corrupt practices. We must ensure that we have robust controls in place so that our records are accurate and transparent.
Employee Responsibility & How To Raise A Concern
The prevention, detection and reporting of bribery or corruption is the responsibility of all employees throughout the firm. If you become aware or suspect that an activity or conduct which is proposed or has taken place is a bribe or corrupt or in breach of this Policy in any way, then you have a duty to report it. You should report it to your manager, or if you feel unable to do this, to the Managing Director or Company Secretary. Any such report must be made in good faith, and the employee making the report will be given the protection of management.