The Bribery Act 2010 modernises the law on bribery. It came into force on 1 July 2011.
The purpose of this policy is to set out for board members and employees of the company the aim of limiting First Response Group exposure to bribery by:
- Setting out a clear anti-bribery policy
- Training all employees and Board members so that they can recognise and avoid the use of bribery by themselves and others
- Encouraging its employees to be vigilant and to report any suspicions of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately
- Rigorously investigating instances of alleged bribery and assisting police and other appropriate authorities in any resultant prosecution
- Taking firm and vigorous action against any individual(s) involved in bribery
Scope
This policy applies to all who work or represent, including suppliers and subcontractors, in any way First Response Group.
The company prohibits
- The offering, the giving, the solicitation, or the acceptance of any bribe, whether cash or other inducement
To or from
- Any person or company, wherever they are situated
By
- Any individual employee, Board Member, agent or other person or body.
In order to
- Gain any commercial, contractual, or regulatory advantage for the Company in a way which is unethical
Or in order to
- Gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual
Further clarification
This policy statement prohibits any inducement which results in a personal gain or advantage to the recipient, or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Company or of the person or body employing them or whom they represent.
This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded and in line with The Bribery Act 2010:
- Normal and appropriate hospitality
- The giving of a ceremonial gift on a festival or another special time
- The use of any recognized fast-track process which is available to all on payment of a fee
- The offer of resources to assist the person or body to make the decision more efficiently provided that they are supplied for that purpose only
Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to your Line Manager. If necessary, guidance should also be sought from a director.
Employee and board responsibility
The prevention, detection and reporting of bribery is the responsibility of all employees, Directors, and Management. Suitable channels of communication by which employees and others can report confidentially any suspicion of bribery will be maintained by the Whistleblowing procedure.
Signed by:
Edgar Chibka Managing Director
Date: 01/04/2022
