(e) offer or accept a gift to or from government officials or representatives, or politicians or political parties;
(f) threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; or
(g) engage in any other activity that might lead to a breach of this policy.
7.
FACILITATION PAYMENTS AND KICKBACKS
7.1
We do not make, and will not accept, facilitation payments or "kickbacks" of any kind.
7.2
Facilitation payments , also known as "back-handers" or "grease payments", are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in the UK, but are common in some other jurisdictions in which we operate.
7.3
Kickbacks are typically payments made in return for a business favour or advantage.
7.4
You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the compliance manager.
8.
GIFTS, HOSPITALITY AND EXPENSES
8.1
This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:
(a) establishing or maintaining good business relationships;
(b) improving or maintaining our image or reputation; or
(c) marketing or presenting our products and/or services effectively.
8.2
You are prohibited from accepting a gift from or giving a gift to a third party is allowed if the following requirements are met:
(a) it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
(b) it is given in our name, not in your name;
(c) it does not include cash or a cash equivalent (such as gift certificates or vouchers);
(d) it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas;
(e) it is given openly, not secretly; and
(f)
it complies with any applicable local law.
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