Anti-Bribery Policy
1. Introduction
1.1. Purpose The purpose of this Anti-Bribery Policy is to outline the commitment of ERPeople Solutions (“The Company") to prevent bribery and corruption in all aspects of its business operations. This policy establishes guidelines and procedures to ensure compliance with the UK Bribery Act 2010 and other relevant anti-bribery laws and regulations.
1.2. Applicability This policy applies to all employees, contractors, consultants, agents, and anyone else acting on behalf of ERPeople Solutions (collectively referred to as "Personnel"). It also extends to business partners, clients, and any third parties with whom the Company engages in business.
2. Policy Statement
2.1. Commitment The Company is committed to conducting its business with honesty, integrity, and transparency. It prohibits all forms of bribery and corruption, both within its own operations and in relation to its business dealings with external parties. The Company expects all Personnel to uphold these principles and to report any suspected or actual instances of bribery or corruption.
2.2. Legal Framework The Company is fully committed to complying with the UK Bribery Act 2010 and all other applicable anti-bribery laws and regulations. It is the responsibility of all Personnel to familiarise themselves with these laws and regulations and to comply with their provisions.
2.3. Zero Tolerance The Company has a zero-tolerance approach to bribery and corruption. Any Personnel found to be involved in bribery or corrupt activities will face disciplinary action, up to and including termination of employment or contractual relationship. The Company may also report suspected violations to the relevant law enforcement authorities.
3. Definitions
3.1. Bribery Bribery refers to the offering, promising, giving, accepting, soliciting, or receiving of any undue advantage, financial or otherwise, with the intention of influencing the actions, decisions, or behaviour of individuals in their official or business capacity.
3.2. Facilitation Payments Facilitation payments are small payments made to expedite routine government actions or services to which an individual or entity is legally entitled.
4. Prohibited Activities
4.1. Bribery and Corruption The following activities are strictly prohibited and will not be tolerated:
4.1.1. Offering, promising, giving, or receiving, directly or indirectly, any form of bribe, kickback, facilitation payment, or other improper advantage to or from any individual or entity, including public officials, clients, suppliers, or competitors.
4.1.2. Using third parties, such as agents, intermediaries, or consultants, to facilitate or conceal bribery or corrupt practices.
4.1.3. Engaging in any activity that could create the appearance of impropriety, compromise the Company's integrity, or undermine fair competition.
4.1.4. Accepting gifts, hospitality, or favours, that are intended to influence or create an obligation beyond reasonable and customary business practices.
4.1.5. Maintaining undisclosed or unrecorded accounts, funds, or assets for any purpose, including facilitating bribes or other corrupt activities.
4.1.6. Involvement in political contributions, donations, or other support that may be construed as bribery or corrupt practices.
4.2. Gifts and Hospitality The Company recognises that the exchange of gifts and hospitality is a common business practice. However, all Personnel must exercise caution and good judgment to avoid situations that may compromise the Company's integrity. Gifts or hospitality must:
4.2.1. Be of modest value and consistent with local customs, norms, and applicable laws.
4.2.2. Not be given or received with the expectation of influencing business decisions.
4.2.3. Be accurately recorded in the Company's books and records.
5. Due Diligence
5.1. Business Partners The Company will conduct appropriate due diligence on all business partners, including clients, suppliers, and intermediaries, to assess their integrity, reputation, and compliance with anti-bribery laws. The level of due diligence will be commensurate with the level of risk associated with the business relationship.
6.0 Reporting and Whistleblowing
6.1. Reporting Obligations All Personnel have a responsibility to report any suspicions or concerns regarding potential bribery or corruption promptly. This includes self-reporting if an individual becomes aware of their own involvement in such activities. Reports should be made to the designated point of contact within the Company.
6.2. Whistleblowing Protection The Company encourages open communication and provides a confidential and anonymous reporting mechanism for reporting suspected or actual instances of bribery or corruption. Whistleblowers will be protected from retaliation and the Company will ensure their confidentiality and anonymity to the extent permitted by law.
7.0 Training and Awareness
7.1. Training Programs The Company will provide regular training and awareness programs to ensure that all Personnel understand their obligations under this policy and are equipped to identify and prevent bribery and corruption risks. Training will be tailored to specific roles and responsibilities within the Company.
8.0 Policy Review
8.1. Policy Review This policy will be periodically reviewed and updated as necessary to ensure its continued effectiveness and compliance with changing laws and regulations.
By adhering to this Anti-Bribery Policy, we demonstrate our commitment to conducting business ethically, maintaining trust with our stakeholders, and preventing bribery and corruption in all its forms