1. Introduction
1.1 Symprex Limited’s policy is to conduct our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
1.2 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
1.3 We will uphold all laws relevant to countering bribery and corruption. We remain bound by the laws of the UK, including the Bribery Act 2010.
1.4 We must work together to prevent bribery and to comply with anti-bribery legislation. This includes reporting situations where you know, or have a reasonable suspicion, that bribery has occurred or is likely to occur.
1.5 This policy does not form part of your contract of employment, and we may amend it at any time. It will be reviewed at least annually but also as and when necessary if new circumstances arise that require the policy to be updated.
2. Bribery and its consequences
2.1 All forms of bribery are strictly prohibited. Bribery includes offering, promising, giving, accepting or seeking a bribe. A bribe is a financial or other inducement or reward (including money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit) for action which is illegal, unethical, a breach of trust or improper in any way. It does not matter whether the bribery occurs in the UK or abroad.
2.2 Specifically, you must not:
(a) give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
(b) accept any offer from a third party that you know, or suspect is made with the expectation that we will provide a business advantage for them or anyone else; or
(c) give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure. You may be told that this is normal practice and that we will be disadvantaged unless we do the same. Such payments are illegal under UK law and no matter the size, we do not offer or pay any facilitation payment.
2.3 You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
3. Gifts and hospitality
3.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services. This normally includes entertaining, meals and tickets to events, but can also include expenses to attend an event or conference.
3.2 As a rule, a gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or if it might influence or be perceived to influence a business decision or could be seen as reward for any preferential treatment (for example, during contractual negotiations or a tender process).
3.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers) or be given in secret. Gifts must be given in our name, not your name.
3.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.
4. Record-keeping
4.1 You must declare and keep a written record of all hospitality or gifts given or received, which will be subject to managerial review.
4.2 You must also 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.
4.3 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.
5. How to raise a concern
5.1 If you are unsure about whether a particular act constitutes bribery, raise it with your manager or Head of Legal.
5.2 If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager or report it in accordance with our Whistleblower Policy as soon as possible.
6. Responsibility for the policy
6.1 The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
6.2 The Head of Legal has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.
6.3 Management at all levels in Symprex are responsible for ensuring those reporting to them understand and comply with this policy.
6.4 Comments, suggestions and queries on this policy are encouraged and should be addressed to the compliance manager.
7. Training
7.1 Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
7.2 This policy must be made available to all employees and staff in Employee Policy Pack.
8. Breaches of this policy
8.1 You will face disciplinary action if you fail to comply with this policy, which could result in dismissal. Failing to comply with this policy could result in you committing a criminal offence.
Last updated: 23 October 2024