8.3
Promotional gifts of low value such as branded stationery to or from existing customers, suppliers and business partners will usually be acceptable.
8.4
Reimbursing a third party's expenses, or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable. We appreciate that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. The intention behind it should always be considered.
8.5
9.
DONATIONS
9.1
We do not make contributions to political parties but these are never made in an attempt to influence any decision or gain a business advantage, and are always publicly disclosed. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the compliance manager.
9.2
10.
RECORD-KEEPING
10.1
We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
10.2
You must declare and keep a written record of all hospitality or gifts given or received, which will be subject to managerial review.
10.3
You must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.
10.4
11.
YOUR RESPONSIBILITIES
11.1
You must ensure that you read, understand and comply with this policy.
11.2
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further "red flags" that may indicate bribery or corruption are set out in paragraph 16.
11.3
12.
HOW TO RAISE A CONCERN
12.1
You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.
12.2
If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager as soon as possible.
19
Made with FlippingBook - Online magazine maker