Flint UK Technology Services Ltd (“the Company”) is committed to the practice of responsible corporate behaviour and to complying with all laws, regulations and other requirements which govern the conduct of our operations.
The Company is fully committed to instilling a strong anti-corruption culture and is fully committed to compliance with all anti-bribery and anti-corruption legislation including, but not limited to, the Bribery Act 2010 (“the Act”) and ensures that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.
Bribery is defined as the giving or promising of a financial or other advantage to another party where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage is in itself improper conduct.Bribery is also deemed to take place if any party requests or agrees to receive a financial or other advantage from another party where that advantage is intended to induce that party to perform a particular function improperly, where the acceptance of that advantage is in itself improper conduct, or where that party acts improperly in anticipation of such advantage.
Bribery of a foreign official is defined as the giving or promising of a financial or other advantage which is intended to influence the official in order to obtain business or an advantage in the conduct of business unless the foreign official is required or permitted by law to be influenced by such advantage.
Anyone or any organisation found guilty of bribery under the Act may face fines and/or prison terms. In addition, high legal costs and adverse publicity are likely to result from any breach of the Act.
For employees of the Company, failure to comply with this Policy and/or with the Act may result in disciplinary action which may include dismissal; and
criminal penalties under the Act which may result in a fine and/or imprisonment for up to 10 years.
For the Company, any breach of this Policy by any employee or business associate may result in the Company being deemed to be in breach of the Act;
the Company being subject to fines; and
the Company suffering negative publicity and further associated damage as a result of such breach.
This Policy applies to all employees, agents, contractors, subcontractors, consultants, business partners and any other parties (including individuals, partnerships and bodies corporate) associated with the Company or any of its subsidiaries.
It is the responsibility of all of the above-mentioned parties to ensure that bribery is prevented, detected and reported and all such reports should be made in accordance with the Company’s Whistleblowing Policy or as otherwise stated in this Policy, as appropriate.
No party described here may:
give or promise any financial or other advantage to another party (or use a third party to do the same) on the Company’s behalf where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage will in itself constitute improper conduct;
request or agree to receive any financial or other advantage from another party where that advantage is intended to induce the improper performance of a particular function, where the acceptance of that advantage will in itself constitute improper conduct, or where the recipient intends to act improperly in anticipation of such an advantage.
Parties described here 4.1 must:
be aware and alert at all times of all bribery risks as described in this Policy and in particular as set out in section 9 below;
exercise due diligence at all times when dealing with third parties on behalf of the Company; and
report any and all concerns relating to bribery to their Line Manager and/or Managing Director or, in the case of non-employees, their normal point of contact within the Company, or otherwise in accordance with the Company’s Whistleblowing Policy.
A facilitation payment is defined as a small payment made to officials in order to ensure or speed up the performance of routine or necessary functions.
Facilitation payments constitute bribes and, subject to section 5.3, may not be made at any time irrespective of prevailing business customs in certain territories.
Facilitation or similar payments may be made in limited circumstances where your life is in danger but under no other circumstances. Any payment so made must be reported to a Company Director as soon as is reasonably possible and practicable.
Save for gifts of low value and which are mere tokens (such as promotional pens, calendars and stationery), excluding money, employees of the Company are not permitted to accept any gifts from customers, suppliers or other third parties involved with the Company.
The Company recognises that there may be exceptional instances when refusing a gift will cause significant offence or embarrassment. In such instances the gift may be accepted and subsequently donated to a charity of the Company’s choice.
Where practicable any employee minded to accept a gift should first seek approval from the Line Manager. If it is not practicable to gain prior approval, the accepting employee should inform a Company Director as soon as possible after receiving the gift.
An accurate record must be kept of all gift offers made to the Company or to employees of the Company by third parties, and must be filed in the “Hospitality and Gifts Register” (“the Register”). Any employee who is offered a gift which is not merely a token should record, as soon as is reasonable practicable:
A description of the gift offered;
An estimation of the value of the gift offered;
Whether it was rejected or accepted;
If accepted, why it was accepted;
Whether prior approval was obtained, and if so, from whom; and
It is anticipated that instances may arise where a gift accepted by the Company or one of its employees has not been donated by the time that the relevant entry is made on the Register. In such cases the Register must be updated within 10 working days of the date on which the donation was made.
Bribery is defined as the giving or promising of a financial or other advantage to another party where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage is in itself improper conduct.
Bribery is also deemed to take place if any party requests or agrees to receive a financial or other advantage from another party where that advantage is intended to induce that party to perform a particular function improperly, where the acceptance of that advantage is in itself improper conduct, or where that party acts improperly in anticipation of such advantage.
Bribery of a foreign official is defined as the giving or promising of a financial or other advantage which is intended to influence the official in order to obtain business or an advantage in the conduct of business unless the foreign official is required or permitted by law to be influenced by such advantage.
“Corporate Hospitality”, for the purposes of this policy, is any form of accommodation, entertainment or other hospitality provided for an employee of the Company by a third party and which is extended to the employee solely or significantly due to his position as a representative of the Company. This excludes the classes of hospitality particularised at paragraph 3.2 below.
For the purposes of this policy and for the sake of clarity, the following are not normally considered Corporate Hospitality and will not require any approval prior to acceptance:
Normal working lunches or refreshments provided during a business visit;
Hospitality extended to employees attending a Company approved seminar, conference or other external event, provided that such hospitality is extended to all who are in attendance;
Free seminars, talks or workshops, provided that they are free to all in attendance and are not provided solely for employees of the Company.
All employees are required to obtain approval before accepting any form of Corporate Hospitality which is offered to them. Approval must be sought from the Line Manager, or where the value of the Corporate Hospitality is likely to be over £50, from the Managing Director.
An accurate record must be kept of all Corporate Hospitality offered to the Company or to employees of the Company for entry on the Register. Any employee offered any form of Corporate Hospitality must record, as soon as is reasonably practicable:
A description of the hospitality offered;
An estimation of the likely value of the hospitality;
Whether it was rejected or accepted;
If accepted, why it was accepted; and
From whom prior approval was obtained.
Charitable donations are permitted only to registered (non-profit) charities. No charitable donations may be given to any organisation which is not a registered charity.
All charitable donations must be fully recorded in the Charitable Donations register.
Proof of receipt of all charitable donations must be obtained from the recipient organisation.
Under no circumstances may charitable donations be made in cash.
No charitable donation may be made at the request of any party where that donation may result in improper conduct.
The Company does not make political donations and the Company is not affiliated with any political party, independent candidate, or with any other organisation whose activities are primarily political.
Employees and other associated parties are free to make personal donations provided such payments are not purported to be made on behalf of the Company and are not made to obtain any form of advantage in any business transaction.
The following issues should be considered with care in any and all transactions, dealings with officials, and other business matters concerning third parties:
Territorial risks, particularly the prevalence of bribery and corruption in a particular country;
Cross-border payments, particularly those involving territories falling under section 9.1;
Requests for cash payment, payment through intermediaries or other unusual methods of payment;
Activities requiring the Company and / or any associated party to obtain permits or other forms of official authorisation;
Transactions involving the import or export of goods;
Compliance with this policy is essential to the protection of the Company’s reputation and that of its employees. Any employee or associate person who is found to have acted in contravention of this policy or its principles may be subject to disciplinary action, including summary dismissal where the breach amount to gross misconduct.
Any employee or any associated person (as defined by Section 8 of the Bribery Act 2010) found giving or receiving bribes or bribing a foreign official will face criminal charges under the provisions of the Bribery Act 2010. Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.
If you have any questions regarding this policy, please get in touch.
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Flint UK Technology Services Ltd
BRE Building 3,Bucknalls Lane,
Watford, Hertfordshire WD25 9XX
Flint Technology Services Ltd
BRE Building 3,Bucknalls Lane,
Garston, Hertfordshire WD25 9XX