EnerBiz Ltd: Anti-Bribery and Corruption Policy
Statement and Purpose of the Policy
As involvement in bribery and corruption exposes EnerBiz Ltd (the Business) and its employees and representatives to criminal offences; damages the Business’ reputation; and damages the confidence of clients, customers, suppliers and business partners, the Business is committed to conducting its business in an honest and ethical manner. Bribery and corruption are criminal offences in most countries where the Business operates. As a UK-registered company, the Business is subject to the Bribery Act 2010. The Business has a zero-tolerance approach towards bribery and corruption anywhere in its business and is committed to:
Acting in a professional and fair manner;
Acting with integrity in all its business dealings and relationships; and
Implementing and enforcing effective systems to counter bribery and corruption.
What Does This Policy Cover?
This policy covers bribery and corruption taking place anywhere in the Business, within the UK or abroad. It sets out the steps everyone in the Business must take to prevent bribery and corruption in accordance with legislation and Business requirements. This policy does not form part of any employment contract and the Business may amend it at its discretion.
What Are Bribery and Corruption?
A bribe is any inducement or reward that is offered, promised, requested or provided in order to gain a commercial, contractual, regulatory or personal advantage. Bribes may include money, gifts, hospitality, entertainment, loans, services, preferential treatment, discounts, or promises of future advantage. Bribery includes giving, offering or promising a bribe, requesting or receiving a bribe, or bribing a foreign public official. Corruption is the misuse of power or office for private gain.
No one working for the Business should:
Offer or provide a bribe;
Accept a bribe;
Offer or provide a payment to a government official to facilitate or speed up a procedure;
Fail to prevent bribery and corruption from occurring;
Intimidate, threaten or retaliate against anyone who refuses a bribe or raises concerns under this policy.
Who Can Be Involved?
Bribery and corruption can be committed by any worker of the Business, regardless of seniority, tenure or role, including employees, directors, officers, consultants, contractors, agency workers, trainees, apprentices, interns and volunteers. It may also involve representatives, suppliers, customers or any third parties acting on the Business’ behalf.
Gifts and Hospitality
All Staff are forbidden from soliciting gifts or hospitality in the course of their work. All Staff are forbidden from offering or receiving gifts or hospitality which are unduly lavish, extravagant or otherwise inappropriate. The following are deemed inappropriate:
Hospitality valued at more than £250;
Gifts with a value greater than £500;
Any gifts including cash or cash equivalents;
Any hospitality or gifts given or received in secret;
Any hospitality or gifts received in the name of an individual rather than the Business.
If you have any questions about gifts and hospitality, contact the Director at admin@enerbiz.co.uk.
Keeping Records
The Business must keep accurate records of all financial dealings. Staff must declare and properly record in writing all hospitality and gifts received or given. In relation to hospitality, gifts or payments to third parties, Staff must submit expense claims and record the reason for the expenditure. All accounts, invoices, purchase orders, credit notes and other records must be accurate and complete.
Reporting Issues Related to Bribery and Corruption
All Staff have a responsibility to comply with this policy and prevent bribery and corruption. Staff must notify their manager as soon as possible if they:
Witness anything corrupt or improper;
Are offered a bribe;
Are asked to offer a bribe;
Suspect or discover that bribery or corruption has occurred or may occur.
Reports may be made anonymously. Any delays in reporting must be explained.
Consequences of Non-Compliance
The Business takes compliance with this policy very seriously. Failure to comply may result in disciplinary action, including dismissal for gross misconduct. Any breach of this policy may constitute a criminal offence and lead to penalties. Non-Staff who breach this policy may have their contracts terminated immediately. Questions or concerns should be directed to the Director at admin@enerbiz.co.uk.