Anti-bribery and Corruption Policy
Updated: 1st January 2025
- Purpose
- 1.1. Bribery and corruption remain major issues in world trade, despite the many dedicated efforts to prevent them. They are very damaging to the societies in which they occur. They:
- divert money and other resources from those who need them most
- hinder economic and social development
- damage business, not least by increasing the cost of goods and services
- 1.2. We run our business Businesses with integrity and in an honest and ethical manner. This policy is a crucial element of that effort. It sets out the steps all of us must take to prevent bribery and corruption in our businesses and to comply with relevant legislation.
- 1.3. We take a zero-tolerance approach to bribery and corruption and will uphold all laws relevant to countering bribery. As a company we remain committed to abiding by the anti-bribery laws of all the jurisdictions in which we operate. We undertake due diligence on our partners, customers and clients and take reasonable steps to ensure that they apply all applicable anti-bribery and anticorruption laws.
- 1.4. The purpose of this policy is to:
- set out our responsibilities in observing and upholding our policy on bribery and corruption; and
- provide information and guidance to our employees, partners, customers and clients, on how to recognise and deal with bribery and corruption issues.
- 1.5. Bribery and corruption harm legitimate business activities and are serious criminal offences. We therefore take our legal responsibilities very seriously.
- 1.1. Bribery and corruption remain major issues in world trade, despite the many dedicated efforts to prevent them. They are very damaging to the societies in which they occur. They:
- Who is covered by the policy?
- 2.1. This policy applies directly to all individuals working in our company. The policy is provided to our other partners, customers and clients, who will be required to take reasonable steps to ensure that in carrying out activities supported by the company, they and their employees, directors and associates comply, with all applicable anti-bribery and anti-corruption laws. In this policy, “third party” means any individual or organisation we come into contact with during the course of our role.
- 2.1. This policy applies directly to all individuals working in our company. The policy is provided to our other partners, customers and clients, who will be required to take reasonable steps to ensure that in carrying out activities supported by the company, they and their employees, directors and associates comply, with all applicable anti-bribery and anti-corruption laws. In this policy, “third party” means any individual or organisation we come into contact with during the course of our role.
- What is covered by the policy?
- 3.1. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
- 3.2. A bribe can take many forms, for example, a direct or indirect promise or offer of something of value, the offer or receipt of a kickback, fee, reward or other advantage, the giving of aid, donations or voting designed to exert improper influence.
- 3.3. Corruption is the misuse of public office or power for private gain or the misuse of private power in relation to business outside the realm of government.
- 3.4. Acts of bribery or corruption are intended to influence an individual in the
performance of their work to act dishonestly and/or improperly. The person being bribed is usually someone who can obtain, retain or direct business for example during a tender or contracting process or it may be through the handling of administrative tasks or customs matters.
- 3.5. Those engaged in bribery and corruption can include an employee, officer or director, any person acting on behalf of the Company who authorise someone else to carry out these acts, Government or public officials whether foreign or domestic.
- 3.1. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
- Gifts & Hospitality
- 4.1. This policy does not prohibit gifts, entertainment, hospitality or other promotional expenditures (given and received) to or from third parties which are proportionate, transparent, reasonable and for bona fide purposes related to the aims and objectives of the Company and do not have a worth more than € 100 per year, per person.
- 4.2. Gifts to a value of more than € 100 a year and per person and comparable value in a different country, should not be given or offered.
- 4.3. The giving or receipt of gifts is not prohibited if all of the following requirements are met:
- it is not made with the intention of influencing a third party to obtain or retain business or
- a business advantage, or to reward the provision or retention of business or a business
- advantage, or in explicit or implicit exchange for favours or benefits.
- it complies with local law.
- it does not include cash or a cash equivalent (such as gift certificates or vouchers).
- it is appropriate in the circumstances. For example, it is given as a ceremonial gift on a
- festival or at another special time (e.g., Christmas);
- taking into account the reason for the gift, it is of an appropriate type and value and given
- at an appropriate time.
- it is given openly, not secretly; and
- gifts should not be offered to, or accepted from, government officials or representatives,
- or politicians or political parties
- 4.4. We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
- 4.1. This policy does not prohibit gifts, entertainment, hospitality or other promotional expenditures (given and received) to or from third parties which are proportionate, transparent, reasonable and for bona fide purposes related to the aims and objectives of the Company and do not have a worth more than € 100 per year, per person.
- Facilitation payments
- 5.1. We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.
- 5.2. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment.
- 5.3. Kickbacks are typically payments made in return for a business favour or advantage. All our partners, clients and suppliers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
- 5.1. We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.
- Your responsibilities
- 6.1. You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Company or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
- 6.2. You must notify your line manager and document as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if a partner, supplier or client offers you something to gain an advantage with us or indicates to you that a gift or payment is required to secure their co-operation with Company supported activities.
- 6.3. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with our partners, clients and suppliers if they breach this policy.
- 6.1. You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Company or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
- How to raise a concern
- 7.1. You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be documented and raised with any member of the Senior Management. Concerns should be reported as a protected disclosure to the Senior Management. Statutory protection of whistle blowers may be afforded under local law.
- 7.1. You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be documented and raised with any member of the Senior Management. Concerns should be reported as a protected disclosure to the Senior Management. Statutory protection of whistle blowers may be afforded under local law.
- Record keeping
- 8.1. We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
- 8.2. You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
- 8.3. 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. No accounts must be kept “off-book” to facilitate or conceal improper payments.
- 8.1. We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
- Protection
- 9.1. Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
- 9.2. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should document and inform a member of Senior Management immediately.
- 9.1. Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
- Risk, Assessment, Monitoring, and Review
- 10.1. As part of the annual policy update process the effectiveness and review the implementation of this policy, considering its suitability, adequacy and effectiveness will be monitored. The annual audits of our control systems and procedures to provide assurance that they are effective in countering bribery and corruption.
- 10.2. All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.
- 10.3. This policy does not form part of any employee’s contract of employment, and it may be amended at any time.
- 10.4. In deciding whether a gift is of comparable value, the relevant employee should consider all surrounding circumstances including, but not limited to, the average income in the location where the recipient of the gift is based.
- 10.5. This Policy applies to all employees of the Unisure Solutions at all times.
- 10.1. As part of the annual policy update process the effectiveness and review the implementation of this policy, considering its suitability, adequacy and effectiveness will be monitored. The annual audits of our control systems and procedures to provide assurance that they are effective in countering bribery and corruption.