Anti-bribery and corruption policy

What is not allowed

• Offering, giving, requesting or accepting anything of value to influence a business decision improperly.
• Facilitation payments and kickbacks, in any amount.
• Charitable or political donations used to obtain a business advantage.
• Using a third party, agent or introducer to do anything this policy forbids.

Gifts and hospitality

Reasonable and proportionate hospitality given or received openly in the normal course of business is acceptable. Anything intended to influence a decision, offered in secret, or lavish in the circumstances is not. Gifts and hospitality above a modest value must be recorded and approved in advance.

Third parties

We carry out proportionate checks on suppliers, partners and introducers, and our contracts require them to comply with anti-bribery law and to allow us to end the relationship if they do not.

Records and reporting

We keep accurate books and records of payments, expenses, gifts and hospitality. Anyone who suspects a breach must report it immediately through their manager or through our whistleblowing route. Nobody suffers a detriment for raising a genuine concern.