Anti Bribery & Corruption Policy
Introduction
City
Moving & Storage values its reputation and is
committed to maintaining the highest level of ethical
standards in the conduct of its business affairs. It
is important to the long term success of the company
that it maintains and protects its reputation for
integrity and honesty in all areas of its business
dealings and that it complies with all relevant laws
and regulations.
This
policy applies strictly to all directors, officers and
employees of City Moving & Storage and all are
expected to be familiar with this and any other such
policies. The company also expects those with whom it
does business to have similar standards and values. It
applies within all regions, areas and functions.
The
Bribery Act 2010
The
Bribery Act 2010 came into force on 1st July 2011. It
sets out the offences of:
§ bribing
another person;
§ requesting,
agreeing to receive, or accepting a bribe from another
person;
§ bribing
a foreign public official;
§ commercial
organisations failing to prevent bribery.
Bribery
can be defined as offering, promising or giving a
financial (or other) advantage to another person with
the intention of inducing or rewarding that person to
act or for having acted in a way which a reasonable
person would consider improper in the circumstances.
Corruption is any form of abuse of entrusted power for
private gain and may include, but is not limited to,
bribery.
Bribes
are not always a matter of handing over cash. Gifts,
hospitality and entertainment can be bribes if they
are intended to influence a decision.
Under
the Act, bribery by individuals is punishable by up to
10 years’ imprisonment and/or unlimited fine. If GB
Liners is found to have taken part in the bribery or
is found to lack adequate procedures to prevent
bribery, it too could also face an unlimited fine.
A
conviction for bribery or corruption related offence
would have severe reputational and/or financial
consequences for the Company.
City
Moving & Storage Policy
City
Moving & Storage will not tolerate bribery or
corruption in any form.
The
Company prohibits the offering, giving, solicitation
or the acceptance of any bribe or corrupt inducement,
whether in cash or in any other form:
§ to
or from any person or company wherever located,
whether a public official or public body, or a private
person or company;
§ by
any individual employee, director, agent, consultant,
contractor or other person or body acting on the
Company’s behalf;
§ in
order to gain any commercial, contractual, or
regulatory advantage for the Company in any way which
is unethical or to gain any personal advantage, in
money’s form or otherwise, for the individual or
anyone connected with the individual.
This
policy is not intended to prohibit the following
practices provided they are appropriate, proportionate
and are properly recorded:
§ normal
hospitality;
§ providing
a ceremonial gift on a festival or at another special
time;
§ fast-tracking
a process when it is available to all on payment of a
fee;
§ providing
resources to assist the person or body to make the
decision more efficiently provided it is for this
purpose only.
It
may not be easy to make a decision if something is
appropriate and remember that market practice varies
between countries. If you are in any doubt that a
potential act does not conform to this Policy, should
should consult the Managing Director or Company
Secretary.
The
Company will investigate thoroughly any actual or
suspected breach of this Policy, or the spirit of this
Policy. Employees found to be in breach of this policy
may be subject to disciplinary action that may
ultimately result in their dismissal.
Gifts
or Inducements
Gifts
or entertainment (including Christmas gifts and
hospitality) given or received by an employee may be
thought of as an improper inducement. Gifts of money
must never be accepted or given. Noncash gifts may be
accepted or given if they are of nominal value (less
than £75) provided they are not capable of being
misconstrued and do not put the recipient under any
obligation.
If
you are offered a cash gift, or a noncash gift of more
than a nominal value, you should inform your manager.
The gift will be entered in the Probity Register and,
unless the Managing Director decides otherwise, will
be donated to charity.
Any
offers of tickets to a sporting, recreational or
cultural event required the consent of the Managing
Director or Company Secretary and full details must be
entered in the Probity Register.
Please
remember there may also be tax implications to the
recipient of gifts.
Reciprocal
Agreements
Reciprocal
agreements or any other form of ‘quid pro quo’ are
never acceptable unless they are legitimate business
arrangements which are properly documented and
approved by management. Improper payments to obtain
new business, retain existing business or secure any
improper advantage should never be accepted or made.
Actions
by Third Parties for Which the Company May Be Held
Responsible
Appropriate
due diligence should be undertaken before a third
party is engaged who will be acting on the Company’s
behalf. This can include agents, contractors,
consultants etc. Third parties should only be engaged
where there is a clear business rationale for doing
so, with an appropriate contract. Any payments to
third parties should be properly authorised and
recorded.
Conflicts
of Interest
Employees
must avoid conflicts of interest between their
activities outside GB Liners and their
responsibilities within the Company. This could
include favouring families or friends in business
dealings, or dealing with a company that is owed by
relatives.
Political
& Charitable Donations
All
employees have a right to their own political views.
The use, however, by individual employees of City
Moving & Storage’s funds or resources for
political purposes is strictly forbidden.
Donations
to charities may be misconstrued in certain
circumstances so the use of City Moving &
Storage’s funds for charitable donations must be
approved by the Managing Director or Company
Secretary.
Competition
City
Moving & Storage is subject to competition law in
all aspects of its operations. The rules not only
apply to us but also to our competitors, suppliers and
customers. Employees must be aware of these laws and
the activities that infringe them, such as agreements
to fix prices or agreements with competitors or
customers, or not to bid for business from certain
companies or in certain geographical areas.
Record
Keeping
Record
keeping can be exploited to conceal bribes or corrupt
practices. We must ensure that we have robust controls
in place so that our records are accurate and
transparent.
Employee
Responsibility & How To Raise A Concern
The
prevention, detection and reporting of bribery or
corruption is the responsibility of all employees
throughout the firm. If you become aware or suspect
that an activity or conduct which is proposed or has
taken place is a bribe or corrupt or in breach of this
Policy in any way, then you have a duty to report it.
You should report it to your manager, or if you feel
unable to do this, to the Managing Director or Company
Secretary. Any such report must be made in good faith,
and the employee making the report will be given the
protection of management.
