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Anti-Bribey & Anti-Corruption Policy
[company
name]
Davidson Holdings Ltd & Subsidiaries
Contents
1. What does your policy cover? ................................................................................3
2. Policy statement ......................................................................................................3
3. Who is covered by the policy? ........................................................................... 3-4
4. Definintion of bribey ..............................................................................................4
5. What is and what is not acceptable ................................................................. 4-6
a. Gifts and hospitality ...............................................................................4-5
b. Facilitation payments and kickbacks .................................................. 5-6
c. Political contributions ................................................................................6
d. Charitable contributions ...........................................................................6
6. Employee Responsibilities .....................................................................................6
7. What happens if I need to aise a concern ...................................................... 7-8
a. How to aise a concern ............................................................................7
b. What to do if you area victim of bribey or corruption ....................7
c. Protection ..............................................................................................7-8
8. Taining and communication ................................................................................. 8
9. Record Keeping .........................................................................................................8
10. Monitoring and reviewing ......................................................................................8
2
1. What does your policy cover?
1.1 This anti-bribery policy exists to set out the responsibilities of [COMPANY NAME] and
those who work for us in regards to observing and upholding our zero-tolerance position on
bribery and corruption.
1.2 It also exists to act as a source of information and guidance for those working for
[DSCOMPANY N.. It helps them recognise and deal with bribery and corruption issues, as
well as understand their responsibilities.
2. Policy statement
2.1 [COMPANY NAME] is committed to conducting business in an ethical and honest
manner, and is committed to implementing and enforcing systems that ensure bribery is
prevented. [COMPANY NAME] has zero-tolerance for bribery and corrupt activities. We
are committed to acting professionally, fairly, and with integrity in all business dealings and
relationships, wherever in the country we operate.
2.2 [COMPANY NAME] will constantly uphold all laws relating to anti-bribery and
corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK,
including the Bribery Act 2010, in regards to our conduct both at home and abroad.
2.3 [COMPANY NAME] recognises that bribery and corruption are punishable by up to
ten years of imprisonment and a fine. If our company is discovered to have taken part in
corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering
for public contracts, and face serious damage to our reputation. It is with this in mind
that we commit to preventing bribery and corruption in our business, and take our legal
responsibilities seriously.
3. Who is covered by the policy?
3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term,
or permanent), consultants, contractors, trainees, seconded sta, home workers, casual
workers, agency sta, volunteers, interns, agents, sponsors, or any other person or persons
associated with us (including third parties), or any of our subsidiaries or their employees,
no matter where they are located (within or outside of the UK). The policy also applies to
Oicers, Trustees, Board, and/or Committee members at any level.
3.2 In the context of this policy, third-party refers to any individual or organisation our
company meets and works with. It refers to actual and potential clients, customers,
suppliers, distributors, business contacts, agents, advisers, and government and public
bodies – this includes their advisors, representatives and oicials, politicians, and public
parties.
3.3 Any arrangements our company makes with a third party is subject to clear contractual
terms, including specific provisions that require the third party to comply with minimum
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4. Definition of bribery
4.1 Bribery refers to the act of oering, giving, promising, asking, agreeing, receiving,
accepting, or soliciting something of value or of an advantage so to induce or influence an
action or decision.
4.2 A bribe refers to any inducement, reward, or object/item of value oered to another
individual in order to gain commercial, contractual, regulatory, or personal advantage.
4.3 Bribery is not limited to the act of oering a bribe. If an individual is on the receiving end
of a bribe and they accept it, they are also breaking the law.
4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be
directly, passively (as described above), or through a third party (such as an agent or
distributor). They must not bribe a foreign public oicial anywhere in the world. They must
not accept bribes in any degree and if they are uncertain about whether something is
a bribe or a gift or act of hospitality, they must seek further advice from the company’s
compliance manager.
5. What is and what is NOT acceptable
5.1 This section of the policy refers to 4 areas:
• Gifts and hospitality.
• Facilitation payments.
• Political contributions.
• Charitable contributions.
5.2 Gifts and hospitality
[COMPANY NAME] accepts normal and appropriate gestures of hospitality and goodwill
(whether given to/received from third parties) so long as the giving or receiving of gifts
meets the following requirements:
a. It is not made with the intention of influencing the party to whom it is being
given, to obtain or reward the retention of a business or a business advantage,
or as an explicit or implicit exchange for favours or benefits.
b. It is not made with the suggestion that a return favour is expected.
c. It is in compliance with local law.
d. It is given in the name of the company, not in an individual’s name.
e. It does not include cash or a cash equivalent (
e.g. a voucher or gift certificate).
f. It is appropriate for the circumstances
(e.g. giving small gifts around Christmas
or as a small thank you to a company for helping with a large project upon
completion).
g. It is of an appropriate type and value and given at an appropriate time, taking
into account the reason for the gift.
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h. It is given/received openly, not secretly.
i. It is not selectively given to a key, influential person, clearly with the intention
of directly influencing them.
j. It is not above a certain excessive value, as pre-determined by the company’s
compliance manager (usually in excess of £100).
k. It is not oer to, or accepted from, a government oicial or representative or
politician or political party, without the prior approval of the company’s
compliance manager.
5.3 Where it is inappropriate to decline the oer of a gift (i.e. when meeting with an individual
of a certain religion/culture who may take oence), the gift may be accepted so long as it is
declared to the compliance manager, who will assess the circumstances.
5.4 [COMPANY NAME] recognises that the practice of giving and receiving business
gifts varies between countries, regions, cultures, and religions, so definitions of what is
acceptable and not acceptable will inevitably dier for each.
5.5 As good practice, gifts given and received should always be disclosed to the compliance
manager. Gifts from suppliers should always be disclosed.
5.6 The intention behind a gift being given/received should always be considered. If there is
any uncertainty, the advice of the compliance manager should be sought.
5.7 Facilitation Payments and Kickbacks
[COMPANY NAME] does not accept and will not make any form of facilitation payments
of any nature. We recognise that facilitation payments are a form of bribery that involves
expediting or facilitating the performance of a public oicial for a routine governmental
action. We recognise that they tend to be made by low level oicials with the intention of
securing or speeding up the performance of a certain duty or action.
5.8 [COMPANY NAME] does not allow kickbacks to be made or accepted. We recognise
that kickbacks are typically made in exchange for a business favour or advantage.
5.9 [COMPANY NAME] recognises that, despite our strict policy on facilitation payments
and kickbacks, employees may face a situation where avoiding a facilitation payment or
kickback may put their/their family’s personal security at risk. Under these circumstances,
the following steps must be taken:
a. Keep any amount to the minimum.
b. Ask for a receipt, detailing the amount and reason for the payment.
c. Create a record concerning the payment.
d. Report this incident to your line manager.
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5.10 Political Contributions
[COMPANY NAME] will not make donations, whether in cash, kind, or by any other
means, to support any political parties or candidates. We recognise this may be perceived as
an attempt to gain an improper business advantage.
5.11 Charitable Contributions
[COMPANY NAME] accepts (and indeed encourages) the act of donating to charities
– whether through services, knowledge, time, or direct financial contributions (cash or
otherwise) – and agrees to disclose all charitable contributions it makes.
5.12 Employees must be careful to ensure that charitable contributions are not used to
facilitate and conceal acts of bribery.
5.13 We will ensure that all charitable donations made are legal and ethical under local
laws and practices, and that donations are not oered/made without the approval of the
compliance manager.
6. Employee Responsibilities
6.1 As an employee of [COMPANY NAME] , you must ensure that you read, understand,
and comply with the information contained within this policy, and with any training or other
anti-bribery and corruption information you are given.
6.2 All employees and those under our control are equally responsible for the prevention,
detection, and reporting of bribery and other forms of corruption. They are required to avoid
any activities that could lead to, or imply, a breach of this anti-bribery policy.
6.3 If you have reason to believe or suspect that an instance of bribery or corruption has
occurred or will occur in the future that breaches this policy, you must notify the compliance
manager.
6.4 If any employee breaches this policy, they will face disciplinary action and could
face dismissal for gross misconduct. [
A Managing Director has the right to terminate a
contractual relationship with an employee if they breach this anti-bribery policy.
7. What happens if I need to raise a concern?
7.1 This section of the policy covers 3 areas:
a. How to raise a concern.
b. What to do if you are a victim of bribery or corruption.
c. Protection.
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7.2 How to raise a concern
If you suspect that there is an instance of bribery or corrupt activities occurring in relation
to [COMPANY NAME] , you are encouraged to raise your concerns at as early a stage as
possible. If you’re uncertain about whether a certain action or behaviour can be considered
bribery or corruption, you should speak to your line manager, the compliance manager, the
director, or the Head of Governance and Legal.
7.3 [COMPANY NAME] will familiarise all employees with its whistleblowing procedures
so employees can vocalise their concerns swiftly and confidentially.
7.4 What to do if you are a vicitim of bribery or corruption
You must tell your compliance manager as soon as possible if you are oered a bribe by
anyone, if you are asked to make one, if you suspect that you may be bribed or asked to
make a bribe in the near future, or if you have reason to believe that you are a victim of
another corrupt activity.
7.5 Protection
If you refuse to accept or oer a bribe or you report a concern relating to potential act(s) of
bribery or corruption, [COMPANY NAME] understands that you may feel worried about
potential repercussions. [COMPANY NAME] will support anyone who raises concerns in
good faith under this policy, even if investigation finds that they were mistaken.
7.6 [COMPANY NAME] will ensure that no one suers any detrimental treatment as
a result of refusing to accept or oer a bribe or other corrupt activities or because they
reported a concern relating to potential act(s) of bribery or corruption.
7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable
treatment in relation to the concern the individual raised.
7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a
concern or refusal to accept a bribe, you should inform your line manager or the compliance
manager immediately.
8. Training and communication
8.1 [COMPANY NAME] will provide training on this policy as part of the induction process
for all new employees. Employees will also receive regular, relevant training on how to
adhere to this policy, and will be asked annually to formally accept that they will comply with
this policy.
8.2 [COMPANY NAME] ’s anti-bribery and corruption policy and zero-tolerance attitude
will be clearly communicated to all suppliers, contractors, business partners, and any third-
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parties at the outset of business relations, and as appropriate thereafter.
8.3 [COMPANY NAME] will provide relevant anti-bribery and corruption training to
employees etc. where we feel their knowledge of how to comply with the Bribery Act needs
to be enhanced. As good practice, all businesses should provide their employees with anti-
bribery training where there is a potential risk of facing bribery or corruption during work
activities.
9. Record keeping
9.1 [COMPANY NAME] will keep detailed and accurate financial records, and will have
appropriate internal controls in place to act as evidence for all payments made. We will
declare and keep a written record of the amount and reason for hospitality or gifts accepted
and given, and understand that gifts and acts of hospitality are subject to managerial review.
10. Monitoring and reviewing
1
0.1 [COMPANY NAME] compliance manager is responsible for monitoring the
eectiveness of this policy and will review the implementation of it on a regular basis. They
will assess its suitability, adequacy, and eectiveness.
10.2 Internal control systems and procedures designed to prevent bribery and corruption are
subject to regular audits to ensure that they are eective in practice.
10.3 Any need for improvements will be applied as soon as possible. Employees are
encouraged to oer their feedback on this policy if they have any suggestions for how it may
be improved. Feedback of this nature should be addressed to the compliance manager.
10.4 This policy does not form part of an employee’s contract of employment and
[COMPANY NAME] may amend it at any time so to improve its eectiveness at
combatting bribery and corruption.
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Completed 23 March 2022

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