Anti-Bribery & Corruption Policy
It is the policy of People Connections to conduct business in an honest and ethical manner. As part of that, People Connections take a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.
The Bribery Act 2010 came into force on 1 July 2011 and creates a framework of five criminal offences:
Giving, promising, and offering of a bribe
Agreeing to receive or accept a bribe
Bribing a foreign official
Failure of commercial organisations to prevent bribery
A senior officer of a commercial organisation consenting to or conniving in an act of bribery
People Connections will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010, which applies to conduct both in the UK and abroad.
This Anti-Bribery and Corruption Policy extends to all business dealings and transactions in the UK. Any breach of the policy is likely to constitute a serious disciplinary, contractual, and criminal matter for the individual concerned. It may also cause serious damage to the reputation and standing of the business.
Gifts and hospitality
This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, any gift or hospitality:
must not be made with the intention of improperly influencing a Third Party or Worker 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;
must comply with local law;
must be given in the name of the company, not in an individual’s name;
must not include cash or a cash equivalent;
must be appropriate in the circumstances;
must be of an appropriate type and value and given at an appropriate time, considering the reason for the gift; and
must be given openly, not secretly.
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. It is not acceptable for any representative of the business to:
give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or People Connections will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;
accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;
accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by People Connections in return;
threaten or retaliate against another member of staff who has refused to commit a bribery offence or who has raised concerns under this policy; or
engage in any activity that might lead to a breach of this policy.
Facilitation payment and ‘kickbacks’
People Connections does not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.
Charitable donations and sponsorship
People Connections only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices.
People Connections maintains appropriate financial records and has appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.
Responsibilities and raising concerns
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for or representing People Connections or under our control. All are required to avoid any activity that might lead to, or suggest, a breach of this policy. All individuals are required to notify People Connections as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.
Further information and guidance
This policy sets out the key principles which People Connections must adhere to. The Bribery Act 2010 can be viewed at: http://www.legislation.gov.uk/ukpga/2010/23/contents
13th June 2020