It is our policy to comply with all laws, rules and regulations governing anti bribery and corruption law, in all the countries in which we operate. We believe it is a fundamental principle of good business practice to respect local laws and customs when operating internationally. However, as a United Kingdom (UK) company, we are also bound by the laws of the UK, which governs our conduct both at home and abroad.
Under UK law, bribery and corruption is punishable for individuals by up to ten years imprisonment and if the company is found to have taken part in corruption it could face an unlimited fine, be excluded from tendering for Government contracts and face untold damage to its reputation. We take our legal obligations in this area very seriously. Under UK law, the offering or receiving of bribes, the making of facilitation payments, the bribery of a foreign public official, and the failure to prevent a bribe being paid on an organisation’s behalf are offences. Such payments are also forbidden under this policy and may result in immediate dismissal for those involved in their payment or receipt. We are required to keep financial records and to have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
This policy applies to individual employees, agents, sponsors, intermediaries, consultants or any other people or bodies associated with our company (ITE) or any of our subsidiaries and employees. Bribery is committed when an inducement or reward is provided in order to gain any commercial, contractual, regulatory or personal advantage for ourselves or another party. Further guidance as to what is regarded by our company as unethical (which includes corrupt) payments can be found in our Ethical Business Practices Policy.
No bribes of any sort may be paid to or accepted from customers, suppliers, politicians, government advisors or representatives, private person or company. It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or influencing transactions.
This policy does not prohibit the following practices providing they are customary in a particular market, or are proportionate and are properly recorded:
• Normal and appropriate hospitality (given or received)
• The giving of a small gift on a festival or at another special time
We recognise that market practice varies across the international arena in which we operate and what is normal and acceptable in one place may not be in another. We also appreciate that to refuse a gift in certain circumstances and/or countries may cause offence to our trading partners. The test to be applied in all circumstances is whether the gift or entertainment is reasonable and justifiable. What is the intention of the gift? Special care must be taken in accepting or giving gifts and/or entertainment and these are not permitted if it would create a real or perceived conflict of interest.
More information can be found in our Gifts & Entertainment Policy.
The prevention, detection and reporting of bribery and corruption is the responsibility of all of our employees. Our Whistle-blowing Policy provides a channel of communication for employees to report confidentially, any suspicion of bribery or corrupt practice.
If anyone is in doubt as to whether a potential act constitutes bribery/corruption, the matter should be referred to line management, Divisional Directors or our Company Secretary.
If you are an external party and wish to raise any concerns, please contact our Company Secretary who will follow-up any matters raised in confidence.
Our Chief Executive Officer has lead responsibility for policy implementation within the Group and this policy is signed by the CEO to demonstrate the Board’s commitment.