Anti-Corruption and Bribery

Parkacre Anti-Corruption and Bribery Policy

1. Purpose and Scope

1.1.  This policy sets out information and guidance on how employees can recognise and deal with bribery and corruption issues.

1.1.1. It is a criminal offence to offer, promise, give, request or accept a bribe under the Bribery Act 2010. Parkacre Ltd has a duty to prevent bribery and corruption.

1.1.2. This policy applies to all:

  • Employees, including those who work part-time or on fixed-term contracts.
  • Contractors, agents, and other third parties working on behalf of and/or representing the company.

 

2. Role & Responsibilities

2.1.  Senior and Departmental Managers have overall responsibility for this policy.

2.1.1.  The Human Resources & Training Manager has day-to-day responsibility for this policy and to ensure the policy is reviewed annually.

2.1.2.  All employees are responsible for following this policy.

 

3. Definition of Bribery

3.1.  Bribery is offering, promising, giving or receiving money or any other advantage to:

  • Encourage the recipient to act improperly.
  • Reward the recipient for acting improperly.

3.1.1. In this context:

  • ‘advantage’ includes money, gifts, loans, hospitality, services, discounts, the award of a contract, etc.
  • a person acts improperly where they act illegally, unethically, impartially or contrary to what is expected, or where they abuse trust.

3.2.  Examples of bribes include:

  • Offering a potential client tickets to a major sporting event, but only if they agree to work with the company.
  • A supplier gives an employee’s family member a job, but makes it clear that in return they expect preferential treatment from the company.
  • Paying an official money to speed up an administrative process. This is sometimes known as a facilitation payment or a kickback.

 

4. Definition of Corruption

4.1.  Corruption is the abuse of power or position for personal gain. For example:

  • Siphoning company money into a personal account.
  • Awarding a contract to family or friends.

 

5. Expectations of Employees

5.1. It is not acceptable for employees to:

  • Offers, give, receive or promise a bribe as defined in this policy.
  • Engage in any activity that could be defined as corrupt.
  • Engage in any activity that is in breach of this policy.

5.2.  If an employee is offered a bribe or learns of any activity that would breach this policy, they must report it immediately to Human Resources & Training Manager.

5.3.  If an employee suspects bribery or corruption but is not sure, they must seek advice from their Line Manager or the Human Resources & Training Manager immediately.   Any reports will be treated confidentially.

5.4.  Employees will not suffer a detriment for refusing a bribe or refusing to engage in corruption.

 

6. Red Flags

6.1.  Employees must report any red flags they come across to their Line Manager or the Human Resources & Training Manager

6.1.1.  A red flag is something that is a cause for concern under this policy. Below are examples of reportable red flags:

  • Becoming aware a third party has engaged in, or has been accused of engaging in, improper business practices.
  • Learning a third party has a reputation for paying bribes or asking for them.
  • A third party insists on receiving a commission or fee payment before committing to signing a contract.
  • A third party requests:
    • To be paid in cash.
    • An additional fee to facilitate a service.
    • A job or other advantage for their family member, friend or contact.
    • A payment is made to a country or location different from where they live or carry out business.
    • To use an agent or intermediary not known to the company.
  • A third party refuses to:
    • Sign a formal agreement or put terms in writing.
    • Provide an invoice or receipt.
  • Receiving a non-standard or customised invoice or receipt from a third party.
  • Receiving an invoice or a commission or fee that appears large given the service provided.
  • Being offered a generous gift or lavish hospitality by a third party.

Please note this list is not exhaustive.

 

7. Donations, Gifts, and Hospitality

7.1.  Parkacre Ltd may choose to donate to charities and local community wellbeing initiatives. These donations are not made to influence decisions or gain commercial advantage.

7.2.  Parkacre Ltd allows corporate gifts and hospitality to:

  • Establish or maintain good business relationships.
  • Improve the image and reputation of the business.
  • Showcase the services of Parkacre Ltd.

However, all gifts and hospitality must be of a reasonable cost and infrequent.

7.2.1.  Examples of gifts and hospitality allowed under this policy are:

  • Paying for a client’s lunch when a meeting or more over the lunch period.
  • Providing a small gift for long-term business contact that is retiring or going on maternity leave.
  • Providing samples of products manufactured by Parkacre to showcase our services and products.

7.3.  Employees must seek authority from the Board or Senior Management Team (SMT) to offer or receive a gift, or hospitality.

7.3.1.  The total amount of gifts or hospitality given or received by an employee cannot exceed £200 in total in 12 month rolling period.

7.4.  All gifts and hospitality must be authorised in advance. Employees must contact the Board or SMT to request authorisation. When doing so, employees must set out in writing:

  • The objective of the proposed expenditure.
  • Details of the proposed expenditure.
  • If hospitality is proposed, dates and who will attend.

7.4.1.  If an employee pays for gifts or hospitality out of their personal account they can be reimbursed through the company expenses procedure.

7.4.2.  An employee will not be reimbursed for personal expenses if:

  • The reason for the gift or hospitality falls outside of the scope of this policy.
  • They did not get prior authorisation for the expenditure.
  • The amount falls outside of the limits of this policy.
  • They do not provide a receipt.

7.4.3.  An employee may also pay for gifts or hospitality through the company credit card. To do this employee should contact Finace Controller who will arrange the payment.

7.5.  If an employee receives an offer of a gift or hospitality from a customer, client, public official, supplier or any other business contact, they must report it immediately to their respective Line Manger.

7.5.1.  The Line Manager will seek guidance from the Human Resources & Training Manager to decide whether the gift or hospitality can be accepted.

7.5.2.  If the Human Resources & Training Manager decides that a gift or hospitality:

  • Can be accepted, they will record it on the gifts and hospitality register.
  • Cannot be accepted, the employee must politely refuse it. The employee’s Line Manager can help them do that.

7.5.3.  Small tokens of appreciation, such as thank you cards, flowers, food packages, or a bottle of wine/spirits do not have to be reported under this policy. However, if an employee is in doubt as to whether a small token should be reported, they should contact their Line Manager for advice.

 

8. Records & Internal Controls

8.1.  The Finance Controller and or Human Resources & Training Manager will keep records of reasons for payments, gifts and hospitality received and offered.

8.2.  Our financial systems are set up so that unusual payments or expense claims are flagged. All receipts and invoices are properly logged so all financial transactions can be traced.

 

9. Breaches of this Policy

9.1.  If any employee breaches this policy, it will be addressed under the company disciplinary procedure.

9.2.  If a contractor, agent, or other third party breaches this policy their contract may be terminated or their contract may not be renewed

 

10. References

  • The Bribery Act 2010

News and Updates

Partner With Us Today

Enquire Now