Corruption and Bribery

Corruption in Office, employment, position or business

This creates an offence for a person, who does any act in relation to their position, for the purpose of corruptly obtaining a gift, consideration or advantage for himself or for any other person. It also creates an offence for a person who uses confidential information for the same purpose.

Giving (and receiving) of Gifts to facilitate an offence

This is defined as giving a gift, consideration or advantage to a person knowing that this will be used to facilitate an offence.

This policy does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality that are given/received in good faith and not offered, promised or accepted to secure an improper advantage for The Company or any of its employees or associated persons. Employees are advised to see our policy on the Acceptance of Gifts.

In certain circumstances gifts and hospitality may amount to corruption. The Company will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a public official in the performance of their duties.

Creating or using a false document

This is defined as a person corruptly creating or using a document knowing / believing it to contain a false / misleading statement with the intention of inducing that person to do an act in relation to their office, employment, position or business, to the prejudice of that person.


This is defined as directly or indirectly threatening to harm another person with the intention of corruptly influencing that person, or another person, to do an act in relation to the person’s office employment, position or business. It sets out a broad definition of harm to include loss, disadvantage or injury of any kind.


A person guilty of an offence under the Act will be liable, on summary conviction, to a fine, imprisonment for a term not exceeding twelve months and forfeiture of the gift, consideration or advantage accepted or obtained in connection with the offence. On indictment, this is subject to a fine or imprisonment for a term not exceeding five years.

Record Keeping

The Company will keep financial records and have appropriate controls in place. All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts should be prepared and maintained with strict accuracy and completeness.

As referenced above, you must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to management review. All expense claims relating to hospitality or gifts, or expenses incurred to third parties, must be submitted in accordance with our expense policy.

Raising a Concern

Employees and associated persons are encouraged to report any concerns that they may have to their line manager, or if this is not appropriate, to an alternative senior manager, as soon as possible.

Any person who has reported an instance or concern of corruption in good faith will be supported by The Company. The Company will ensure that the individual is not subjected to detrimental treatment as a result of raising a corruption concern.

Monitoring and Training

The Company will regularly review the effectiveness of this policy. Training sessions will be arranged for appropriate individuals where necessary to ensure staff know how to recognise, and deal with, suspected bribery and corruption. The Company will take all reasonable steps and exercise all due diligence to avoid the commission of an offence. The Company reserves the right to amend and update this policy as required.