Document Reference: IM 04 Anti Bribery and Corruption Policy
business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties. Any arrangements The Company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption. Definition of bribery Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision. A bribe refers to any inducement, reward, or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law. Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from The Company’s Finance Manager. Gifts and hospitality The Cox Group accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements: a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits. b. It is not made with the suggestion that a return favour is expected. c. It is in compliance with local law. d. It is given in the name of the company, not in an individual’s name. e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate). f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion). g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift. h. It is given/received openly, not secretly.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 12 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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