Gilt Edged Promotions Ltd 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, you should consult the Managing Director or Director of the Company.
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. Non-cash 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 non-cash 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 Director 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 Gilt Edged Promotions 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 Gilt Edged funds or resources for political purposes is strictly forbidden.
Donations to charities may be misconstrued in certain circumstances so the use of Gilt Edged funds for charitable donations must be approved by the Managing Director or Company Director.
Competition
Gilt Edged 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 Director. Any such report must be made in good faith, and the employee making the report will be given the protection of management.