The Bribery Act 2010 came into force on 1 July 2011 and it is our policy to conduct all of 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 dealings wherever we operate. We are also committed to implementing and enforcing effective systems to counter bribery.
This policy applies to all individuals working at all levels and grades, including senior managers, directors, colleagues (whether permanent, fixed-term or temporary), consultants, contractors, and any other persons providing services to Exel Contracts.
What is a Bribe?
A bribe is a financial or other advantage offered or given:
• to anyone to persuade them to or reward them for performing their duties improperly or;
• to any public official with the intention of influencing the official in the performance of his duties.
Gifts and Hospitality
This policy does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality. However, in certain circumstances gifts and hospitality may amount to bribery and all Colleagues must comply strictly with Exel Contracts Ethics in respect of gifts and hospitality. We 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 his duties
Facilitation payments and kickbacks
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Kickbacks are typically payments made in return for a business favour or advantage. All colleagues must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
Donations
We do not make contributions of any kind to political parties. No charitable donations will be made for the purpose of gaining any commercial advantage.
Compliance with anti-bribery and corruption laws
Complaints that count as whistleblowing
You’re protected by law if you report any of the following:
- a criminal offence, for example fraud
- someone’s health and safety is in danger
- risk or actual damage to the environment
- a miscarriage of justice
- the company is breaking the law, for example does not have the right insurance
- you believe someone is covering up wrongdoing
Raising Concerns
Colleagues will be encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. No colleague will suffer any detriment as a result of raising genuine concerns about bribery, even if they turn out to be mistaken.
If a colleague has a concern they wish to raise, they should contact the Director, or, if there is a conflict, the Managing Director.
Investigations within Exel Contracts Ltd
Senior management will ensure that on induction of all members of staff they will be made aware that Exel Contracts operates a zero tolerance on any form of bribery or corruption. Any staff member or member of the management team found to be subject to this will be fully investigated and if found to be guilty then the disciplinary procedure will be invoked.
Competition Law
In the UK anti-competitive behaviour is prohibited under Chapters I and II of the Competition Act 1998 (the Act) and may be prohibited under Articles 81 and 82 of the EC Treaty. These laws prohibit anti-competitive agreements between businesses and the abuse of a dominant position in a market.
Exel Contracts is committed to working within the guidelines as per the Office of Fair Trading (OFT) advice (copy available upon request). All employees and the management team at Exel Contracts is fully aware of competition law and recognises the need to comply.
There are four main features that are included as a minimum for a programme to work effectively. Exel Contracts fully supports these.
They are:
• the support of senior management
• appropriate policy and procedures
• training
• regular evaluation
The management of Exel Contracts Ltd is committed to the following 6 principles:
- Proportionality
- Top level commitment
- Risk assessment
- Due diligence
- Communication
- Monitoring and review
