Document Reference: IM 04 Anti Bribery and Corruption Policy
i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them. j. It is not above a certain excessive value, as pre-determined by the company’s Finance Manager (usually in excess of £100). k. It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s Finance Manager. Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the Finance Manager, who will assess the circumstances. The Company recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. As good practice, gifts given and received should always be disclosed to the Finance Manager. Gifts from suppliers should always be disclosed. The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the Finance Manager should be sought. Facilitation Payments and Kickbacks The Cox Group does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action. The Cox Group does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage. The Cox Group recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their family’s personal security at risk. Under these circumstances, the following steps must be taken: a. Keep any amount to the minimum. b. Ask for a receipt, detailing the amount and reason for the payment. c. Create a record concerning the payment. d. Report this incident to your line manager.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 12 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
3
Made with FlippingBook Digital Publishing Software