Anti-Bribery & Corruption Policy
Anti-bribery and corruption policy
1.1 Bribery and corruption remain major issues in world trade, despite the many dedicated efforts to prevent them. They are very damaging to the societies in which they occur. They:
1.1.1 divert money and other resources from those who need them most;
1.1.2 hinder economic and social development;
1.1.3 damage business, not least by increasing the cost of goods and services.
1.2 At EM Distribution (PTY) Ltd (“EM”, “we” and “our”) our legal obligations are primarily governed by the Bribery Act 2010 (BA 2010). BA 2010 affects us as a UK organisation if bribery occurs anywhere in our business.
1.3 We run our business with integrity and in an honest and ethical manner. All of us must work together to ensure EM remains untainted by bribery or corruption.
1.4 This policy is a crucial element of that effort. It has the full support of the Board. It sets out the steps all of us must take to prevent bribery and corruption in our business and to comply with relevant legislation.
1.5 If you have any questions on this policy, please contact your line manager.
2 What are bribery and corruption?
2.1 Corruption is the misuse of office or power for private gain.
2.2 Bribery is a form of corruption. It includes offering, promising, giving, accepting or seeking a bribe.
2.3 A bribe is a financial or other advantage, promised, requested or given to induce a person to perform a relevant function or activity improperly, or to reward them for doing so.
2.4 In practical terms, a financial or other advantage is likely to include cash or cash equivalent, gifts, meals, entertainment, services, loans, preferential treatment, discounts or anything else of value.
2.5 The timing of the bribe is irrelevant and payments made after the relevant event will still be caught, as will bribes that are given or received unknowingly.
2.6 It is not necessary for the individual or organisation to actually receive any benefit as a result of the bribe.
2.7 This means that you must not:
2.7.1 give or offer any payment, gift, hospitality or other benefit that could amount to a bribe, eg in the expectation that a business advantage will be received, or to reward any business obtained or retained; or
2.7.2 accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else.
2.8 All forms of bribery and corruption are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your line manager.
2.9 No person must threaten or retaliate against another person who has refused to offer or accept a bribe or who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
3 Who can be involved in bribery and in what circumstances?
3.1 Bribery and corruption may be committed by our:
3.1.1 staff (employees, directors etc) or anyone they authorise to do things on our behalf;
3.1.2 representatives and other third parties who act on our behalf;
3.1.4 customers (because they might try to induce one of our people to give them more favourable terms).
3.2 Bribery can occur in both the public and private sectors. The person receiving the bribe is usually in a position to influence the award or the progress of business, sometimes a government or other public official.
4 The legal position on bribery
4.1 Bribery and corruption are criminal offences in most countries where we do business. UK businesses, including this one, are subject to BA 2010. Under BA 2010 it is illegal to:
4.1.1 pay or offer to pay a bribe; and
4.1.2 receive or agree to receive a bribe.
4.2 A commercial organisation can also commit an offence if a person associated with it bribes another and does so with the intention of obtaining or retaining business or a business advantage for the organisation.
4.3 It does not matter whether the bribery or corruption occurs in the UK or abroad. An act of bribery or corruption committed abroad may well result in a prosecution in the UK. Nor does it matter whether the act is done directly or indirectly.
5.1 Our position is simple: we conduct our business to the highest legal and ethical standards. We will not be party to corruption or bribery in any form. Such acts would damage our reputation and expose us, and our staff and representatives, to the risk of fines and imprisonment. We take a zero-tolerance approach to bribery and corruption by our people and our third party representatives.
5.2 Bribery and corruption may be more widespread in some countries and business sectors than others. In some cases you may be told that unless we pay bribes we will not win business. That does not matter. If we were to be involved in even one instance of bribery or corruption, we would have shown that we engage in such conduct. We do not.
6 Acting with integrity—benefits and consequences
The following sets out some of the benefits of acting with integrity and some of the possible consequences of not acting with integrity:
Benefits of acting with integrity
Increased chances of being selected as a supplier in public and private sectors.
Other business will want to work with us.
Remain in good standing with our banks and own suppliers.
People will be more likely to want to work for us.
Protected reputation.
Consequences of not acting with integrity
A business that pays or accepts bribes is not in control of its dealings and is at risk of blackmail.
If the business is found guilty of bribery, or if it fails to put in place adequate procedures to prevent it, could be subject to large fines.
Any person guilty of bribery will be subject to fines and/or imprisonment (up to ten years under BA 2010).
An allegation of bribery or corruption would result in severe reputational damage.
Our share price would almost certainly drop.
The cost of our insurance cover could increase very significantly.
Banking or supply facilities might be withdrawn or offered only on less favourable terms.
Being restricted for tendering for private and public sector contracts.
Good people will not want to work for us.
7 What are indicators of corruption and bribery?
7.1 Common indicators of bribery and corruption include:
7.1.1 payments are for abnormal amounts or purposes (eg commission), or made in an unusual way, eg what would normally be a single payment is made in stages, through a bank account never previously used, or in a currency or via a country which has no connection with the transaction;
7.1.2 process is bypassed for approval or sign-off of terms or other commercial matters, or we are prevented from or hindered in monitoring commercial processes;
7.1.3 individuals are secretive about certain matters or relationships and/or insist on dealing with them personally; they may make trips at short notice without explanation, or have a more lavish lifestyle than expected;
7.1.4 decisions are taken for which there is no clear rationale;
7.1.5 records are incomplete or missing.
8.1 We aim to ensure our anti-bribery and corruption procedures are proportionate to the risks we face.
8.2 We have performed an assessment of the risk of our organisation being exposed to bribery and corruption. This Anti-bribery and corruption policy has been developed in response to the results of that risk assessment. Where necessary, we will review our risk assessment and make appropriate changes to this policy.
8.3.1 We have identified certain aspects of our business where we are presented with a higher risk than others. These include:
(a) gifts and hospitality: covered in our Gifts and hospitality policy (please see Appendix 1);
(i) also known as ‘grease’ payments;
(ii) usually small amounts paid to officials to provide goods or services to which we are already entitled, eg speeding up the grant of a licence or permit;
(iii) common in many countries, particularly those where public officials are poorly paid;
(v) we do not offer or pay them;
(vi) if you are faced with a request, or a demand, please contact your line manager immediately;
(c) agents and intermediaries: covered in our Agents and intermediaries policy (please see Appendix 2);
(d) commissions - all commissions constitute the giving of a financial advantage, although they will not necessarily be bribes;
(e) charitable and political donations: covered in our Charitable and political donations policy (please see Appendix 3).
We understand that people in different parts of the world have different social and cultural customs. This does not affect our stance that we do not pay or accept bribes or act corruptly: we do not and will not. However, subject to that position, we understand the need to be sensitive to local customs, eg there are cultures in which refusing (or failing to offer) a gift is considered impolite, and could alienate a key contact or customer.
It is essential that we keep full and accurate records of all our financial dealings. Transparency is vital; false or misleading records could be very damaging to us.
10 Who is responsible for this policy?
The Board has overall responsibility for this policy. It is responsible for ensuring this policy is adhered to by all staff.
11.1 Everyone in the organisation is responsible for:
11.1.1 reading and being aware of the contents of this policy;
11.1.2 complying with this policy;
11.1.3 reporting cases where you know, or have a reasonable suspicion, that bribery or corruption has occurred or is likely to occur.
11.2 We will not penalise anyone who loses business through not paying a bribe.
12 What should you do if you think something is wrong?
12.1 Each of us has a responsibility to speak out if we discover anything corrupt or otherwise improper occurring in relation to our business (see 11.1.3). We cannot maintain our integrity unless we do this. If you discover or suspect bribery or corruption, whether by:
12.1.1 another staff member, or a third party who represents us;
12.1.2 one of our suppliers or competitors;
12.1.3 anyone else - perhaps even a customer;
you must report your concerns to your line manager or otherwise to a Director.
12.2 You can do this anonymously.
12.3 You must make your report as soon as reasonably practicable. You may be required to explain any delays.
All staff will receive training on this and related policies. New joiners will receive training as part of the induction process. Further training will be provided at least every two years or whenever there is a substantial change in the law or our policy and procedure.
14.1 Everyone must observe this policy. It will count for nothing unless we do.
14.2 The Board has overall responsibility for this policy. It will monitor it regularly to make sure it is being adhered to. In doing this it acts in the interest of our business as a whole, and it is therefore the responsibility of all of us to help the Board in this.
15 Consequences of failing to comply
15.1 We take compliance with this policy very seriously.
15.2 Failure to comply puts both you and the business at risk.
15.3 You may commit a criminal offence if you fail to comply with this policy. The criminal law relating to bribery and corruption carries severe penalties.
15.4 Because of the importance of this policy, failure to comply with any requirement may lead to disciplinary action under our procedures, and this action may result in dismissal for gross misconduct.
15.5 If you have any questions or concerns about anything in this policy, do not hesitate to contact your line manager.
1.1 At EM Distribution (PTY) Ltd (“EM”, “we” and “our”) we run our business with integrity. All of us must work together to ensure our business remain untainted by bribery and corruption. This policy is integral to that effort and we are all bound by it.
1.2 Almost every business engages in some form of corporate hospitality to existing or potential business partners or clients.
1.3 Gifts and hospitality encompass a range of activities, from providing pens marked with company logos, to providing charter flights to foreign countries or expansive (and expensive) meals and entertainment. We need to ensure that corporate hospitality does not tip over into bribery or corruption.
1.4 The problem is that the Bribery Act 2010 itself does not provide any direct assistance on what is acceptable and what is not. So, knowing what you can and cannot properly do can therefore be difficult.
1.5 You should be aware that bribery and corruption is an area where perception can sometimes be more important than fact. Regardless of whether a gift or hospitality has been offered or accepted with purely innocent motives, if an external observer could put an adverse construction on that gift or hospitality, it puts the business - and the person giving or receiving the gift/hospitality - at risk.
1.6 This policy contains controls to minimise this risk but we rely on staff to exercise judgement about how any gift/hospitality might be perceived, recognising that what at first sight might appear to be reasonable might nevertheless become the subject of unreasonable comment or criticism by external parties.
1.7 This policy covers the offer or receipt of gifts or hospitality and our internal notification and record keeping requirements. It sits alongside and should be read in conjunction with our Anti-bribery and corruption policy.
2 Offer and receipt of gifts and hospitality
2.1 You must not solicit, accept, offer or give gifts or hospitality that may influence or appear to influence the recipient’s ability (or any relevant third party’s ability) to make objective business decisions.
2.2 You must not offer or receive from any person or organisation any gift or hospitality that:
2.2.1 is unduly lavish or extravagant or otherwise inappropriate; or
2.2.2 could be seen as an inducement or reward for any preferential treatment.
2.3 We regard the following to be inappropriate (the list is not exhaustive):
2.3.1 a personal or corporate gift to a value in excess of £100;
2.3.2 hospitality to a value in excess of £200;
2.3.3 any gift or hospitality given or received in secret;
2.3.4 any gift or hospitality given in or received in the name of an individual rather than the Company, or any part of our business;
2.3.5 any gift that is in cash, or cash equivalent (eg gift cards);
2.3.6 gifts or hospitality offered where there is an expectation that the business relationship will be influenced or in exchange for something in return (quid pro quo);
2.3.7 any gift or hospitality given at a time when you and the other party are negotiating a contract or are in a related vendor selection process;
2.3.8 any pattern of giving frequent gifts or hospitality, even if of nominal value;
2.3.9 any gift or hospitality where the timing is such that it appears to be offered in exchange for favourable treatment;
2.3.10 indecent or sexually oriented gifts or hospitality;
2.3.11 any gift or hospitality that is illegal or breaches any of our policies;
2.3.12 any gift or hospitality that could adversely impact our reputation;
2.3.13 any gift or hospitality to a customer’s employee where you know a customer’s policies prohibit or limit giving gifts or hospitality to that customer’s employees.
2.4 EM regards the giving or receiving of hospitality where the person providing the hospitality does not themselves attend the event as unusual in the context of our business. If you are offered, or planning to offer such hospitality, you must first consult with your line manager.
2.5 The monetary limits in clauses 2.3.1 and 2.3.2 are intended as a maximum. Depending upon the circumstances, a gift of a lesser amount could still be or be perceived as a bribe, as could several small gifts to the same person.
2.6 EM forbids any employee from offering or receiving any gift or hospitality that is in breach of relevant law.
2.7 You must not solicit gifts or hospitality of any kind.
2.8 The Board may exercise its discretion to permit gifts or hospitality which exceed the threshold limit stated above - see clauses 2.3.1 and 2.3.2.
2.9 If you are in doubt, please contact your line manager.
3 Notifying/recording gifts/hospitality within the monetary limit
3.1 You must inform your line manager of all gifts and hospitality made or received within the monetary limits set out above. The details will then be recorded in a central gifts and hospitality register. (See clause 4 for gifts/hospitality over the monetary limit.)
3.2 The gifts and hospitality register is reviewed and monitored by the Board.
4 Gifts/hospitality over the monetary limit
4.1 If you receive or wish to give a gift or hospitality valued at more than the monetary limits set out above, you must inform your line manager. The details will then be recorded in a central gifts and hospitality register and the Board notified.
4.2 Rather than allow you to accept hospitality or keep a gift that exposes you and/or the Company to risk, you may be required to decline hospitality or return higher-valued gifts, or to donate them to charity, or the Company may apply the gift for corporate use.
4.3 Remember: even lower value gifts and hospitality are inappropriate if they are repeated or are intended to (or may appear to) improperly influence the recipient.
5 Refusing a gift or hospitality
5.1 Where a gift or hospitality prohibited by this policy is offered to or received by a member of staff it should be refused.
5.2 EM recognises that in certain situations it can be considered impolite to refuse a gift or hospitality. It is therefore important that gifts/hospitality are refused in a manner sensitive to all the circumstances so as to avoid causing any offence, eg by:
5.2.1 thanking the giver for their thoughtfulness, taking care not to embarrass them; and
5.2.2 expressing your apologies for not accepting the gift/hospitality and explaining why, mentioning this policy and specific rules, as necessary.
5.3 If you receive a gift or hospitality from a supplier or other third party that exceeds the threshold limit stated above, or may seem to create a conflict, and you are concerned that either returning the gift or paying for the gift or hospitality may insult the party giving it and therefore have a negative effect on the business relationship, you must report it to your line manager.
5.4 If a gift has already been received and the giver refuses to take it back, the gift should be handed to your line manager.
6.1 Everyone has a responsibility to speak out if they suspect bribery or corruption or are aware of any gift or hospitality given or received which may be in breach of this policy. Any concern in respect of such a breach by:
6.1.1 another member of staff;
6.1.2 a third party who represents us;
6.1.3 one of our suppliers or competitors; or
6.1.4 anyone else (even a client/customer seeking better terms from us).
must be reported to the Board or through the Whistleblowing procedure. This can be done anonymously.
6.2 EM will investigate all allegations immediately and thoroughly and properly end the relationship if appropriate.
7.1 EM is responsible for this policy.
7.2 Compliance with this policy is a condition of every employee’s contract. Every employee is responsible for reading and knowing the contents of this policy.
7.3 You must not seek to circumvent the provisions of this policy, eg by personally paying for a gift or hospitality to avoid having to report or seek approval for it.
7.4 If any member of staff has any questions on this policy, they should contact their line manager.
7.5 You may be liable to disciplinary action if you fail to comply with or seek to circumvent the provisions of this policy.
1.1 At EM Distribution (PTY) Ltd (“EM”, “we” and “our”) we run our business with integrity. All of us must work together to ensure our business remains untainted by bribery and corruption and other financial crime, eg facilitation of tax evasion. This policy is integral to that effort and we are all bound by it.
1.2 This policy covers the use of agents and intermediaries (which we will refer to in this policy as “Agents”) who help with our business. It sets out the due diligence steps required before and during the engagement of an Agent to ensure the use of such an Agent does not improperly affect our business.
1.3 This policy sits alongside and should be read in conjunction with our Anti-bribery and corruption policy.
1.4 What is an agent or intermediary?
1.4.1 Agents are third parties engaged to provide services for or on behalf of the Company or represent our interests.
1.4.2 They may include (i) business consultants; (ii) sales agents; (iii) third parties retained in relation to government business; (iv) introducers; (v) facilitators; and (vi) lawyers, accountants and other professional advisors.
1.5 Application of the law to Agents and the risks they present
1.5.1 The Bribery Act 2010 (BA 2010) prohibits (i) active bribery, eg offering, promising or giving a bribe; (ii) passive bribery, eg agreeing to receive or accepting a bribe; and (iii) bribery of a foreign public official.
1.5.2 The offences can be committed by individuals or organisations and may be direct (directly making a bribe), or indirect (eg making a bribe through a third party).
1.5.3 BA 2010 also creates a corporate offence for commercial organisations that fail to prevent bribery on their behalf - unless they have in place adequate procedures to prevent bribery.
1.5.4 Critically, EM can be held liable for acts of bribery by “associated persons”.
1.5.5 Agents who perform services for or on behalf of a commercial organisation are associated persons within the meaning of section 8 of the Bribery Act 2010 (BA 2010).
1.5.6 If an associated person bribes another person intending to obtain or retain business, or an advantage in the conduct of business for EM, we will be guilty of an offence unless we can show we have adequate procedures to prevent bribery.
1.5.7 A bribery offence could also be committed if a payment is made to an Agent knowing that all or part of that payment will be used to pay bribes.
1.5.8 ‘Knowing’ includes more than actual knowledge - it can include (i) conscious disregard; (ii) wilful blindness; (iii) deliberate ignorance of facts that put you on notice.
1.5.9 Suggested procedures include those set out in this policy and it is critical that they are followed.
2.1 As we can be held liable for bribery committed or facilitated by an Agent while acting on our behalf, we must be confident before retaining an Agent (and throughout the business relationship) that they will not engage in bribery.
2.2 This involves (i) conducting due diligence on the Agent to learn about their background, experience, etc; and (ii) obtaining the Agent’s written agreement to abide by all applicable anti-bribery laws and our related policies.
3.1 The process for conducting due diligence varies depending on the level of perceived risk presented by each Agent. The three key elements to conducting due diligence are (i) collect data from or about the Agent; (ii) verify and validate that data; and (iii) evaluate results, including identifying red flags.
3.2.1 The objective of the data collection process is to assemble and document relevant information about the structure, ownership and operations of the Agent, its reputation for and commitment to integrity, and its suitability for the type of business relationship being considered.
3.2.2 The following table contains details of factors we consider raise a higher probability of improper conduct by an Agent:
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FATAL red flags |
NON-FATAL red flags |
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The Agent refuses to agree to confirm compliance with applicable international bribery laws and EM’s anti-bribery and corruption policy. The Agent insists on contractual provisions or undocumented arrangements that violate EM’s policy. The Agent insists on cash payments or payments to unrelated offshore bank accounts. Any previous convictions for bribery or similar criminal offences. The Agent has previously requested another organisation to prepare false invoices or other types of false documentation. The Agent refuses to disclose adequate information about its ownership, personnel or business, or fails to respond adequately to our due diligence processes. |
Any indication (such as through Internet searches, reputation or reference checks) that the proposed Agent has engaged in unethical or illegal conduct. The Agent has asked for unusual financial arrangements, such as cash payments, advance payments, payments to another party or invoices or payments to an address or bank account outside the country where its activities are performed or its offices are located. The Agent has refused to provide information in response to our requests. The Agent shares common directors or owners with a customer of EM. The Agent is separately remunerated by a customer or is a trusted adviser to them. The Agent is based in a tax haven or a country with a strong reputation for corruption. The Agent charges commissions or fees that are out of proportion to the value of the underlying services. The Agent wants to keep their representation of EM secret. Negative feedback from references |
3.2.3 The existence of a non-fatal red flag does not automatically mean we cannot go ahead with the third-party business relationship. Non-fatal red flags may be resolved with additional due diligence.
3.2.4 Fatal red flags are so serious and pose so high a risk that they cannot be resolved and must lead to the immediate cessation of existing business relationships or the engagement process.
4.1 Once due diligence is successfully completed and an Agent is engaged, we will monitor and reaffirm the appropriateness of the relationship on an ongoing basis.
4.2 A starting point is that during the engagement of an Agent EM must retain documentary evidence of all instructions given to the Agent as part of its ordinary business records.
4.3 Periodic due diligence must also be completed at least every 2 years or with greater frequency where:
4.3.1 there are any indicators or evidence of heightened risk as per the table of red flags at 3.3.2;
4.3.2 the contract with the Agent is scheduled for renewal.
4.4 Periodic due diligence involves taking the same due diligence steps set out above.
5.1 We will obtain a clear written agreement defining the service that the Agent is to provide.
5.2 All Agent contracts must include the Agent’s agreement to: (i) abide by local and international laws and to comply with EM’s prohibition against bribery; and (ii) produce documents and information on request to verify compliance and update due diligence and to allow audits as deemed appropriate.
6.1 Every staff member has a responsibility to speak out if they suspect bribery or corruption or are concerned about an Agent’s behaviour or demands. Such concern must be reported to the Board. This can be done anonymously.
6.2 EM will investigate all allegations immediately and thoroughly and properly end the relationship if appropriate.
7 Compliance with this policy
7.1 The Board is responsible for this policy.
7.2 Compliance with this policy is a condition of each employee’s employment contract. Every employee is responsible for reading and understanding the contents of this policy. You may be liable to disciplinary action if you fail to comply with the provisions of this policy.
7.3 If any staff member has any questions on this policy, they should contact their line manager or the Board.
1.1 At EM Distribution (PTY) Ltd (“EM”, “we” and “our”) we run our business with integrity. All of us must work together to ensure our business remains untainted by bribery and corruption. This policy is integral to that effort and we are all bound by it.
1.2 EM takes pride in its support of charities and good causes and is committed to conducting itself with the highest standards of probity in continuing to offer such support.
1.3 Bribery and corruption is, however, an area where perception can sometimes be more important than fact. Corrupt payments can be disguised as charitable and political donations. Regardless of whether a donation has been made with purely innocent motives, if an external observer could put an adverse construction on that donation, it puts the business, and the person receiving the donation, at risk.
1.4 This policy contains controls to minimise this risk but we rely on staff to exercise judgement about how any donation might be perceived, recognising that what at first sight might appear to be reasonable might nevertheless become the subject of unreasonable comment or criticism by external parties.
1.5 This policy covers charitable and political donations made by EM or on its behalf and our internal notification and record keeping requirements. This is to ensure that all donations are legitimate and properly recorded and do not improperly affect this organisation.
2.1 A charitable donation is a gift made by an individual or company to a non-profit organisation or charity. A charity means any body of persons or trust established for charitable purposes only.
2.2 Charitable donations are commonly in the form of cash or other assets.
2.3 Bribes may be disguised as charitable donations. For that reason, any donations this organisation makes require prior approval. See section 5.
2.4 While individuals may of course make personal donations to charity, they must not do so on behalf of this organisation without prior approval. See section 4.
3.1 Political donations are contributions made to a politician, a political campaign or a political party.
3.2 You should be aware that such contributions can be (or be seen as) bribes in disguise.
3.3 We do not make donations to political parties.
3.4 No individual is to make a political donation stated to be, or which could be taken to be, on behalf of this organisation without prior approval, (see section 5).
3.5 You may, of course, make political donations in a personal capacity, but please be sensitive to how such contributions could be perceived, especially by those who are aware of your connection with this organisation, (see section 4).
4 Personal political donations
4.1 This policy is not intended to interfere with your individual personal political donations. You may make personal political contributions and be involved in political activity in your own time.
4.2 However, you must not make personal political donations where:
4.2.1 they could be connected, or be seen to be connected, with a decision by a public sector body in relation to EM’s business;
4.2.2 they could be mistaken to be for the activities of EM;
4.2.3 company time, property or equipment is needed to carry out or support your personal political activities.
4.3 EM is completely independent of any personal political donations and will never pay, reimburse, co-ordinate or organise these types of donation, and you must always make clear that your views and actions are your own and not those of EM.
5.1 EM forbids any employee directly or indirectly from making an offer of, or making a donation to, any charitable, non-profit or political organisation in the course of their employment as a way to obtain an advantage in a business transaction or other business matter.
5.2 EM may exercise its discretion to permit charitable or political donations through this approval process.
5.3 To seek approval, employees must submit a charitable donations approval request form.
5.4 EM will undertake an initial screening exercise on all approval requests. This will include considering (i) the intention behind the donation; (ii) the perception; and (iii) the legal and regulatory environment.
5.5 As with all due diligence, the level of enquiry depends on the circumstances, and will be reasonable and proportionate.
We will ensure all charitable or political donations are accurately recorded.
7 Reporting concerns
7.1 Everyone has a responsibility to speak out if they suspect bribery or corruption or are concerned about a charitable or political donation. Any such concern must be reported to the Board or follow the Whistleblowing procedure. This can be done anonymously.
7.2 EM will investigate all allegations immediately and thoroughly.
8 Compliance with this policy
8.1 EM is responsible for this policy.
8.2 Compliance with this policy is a condition of each employee’s employment contract. Every employee is responsible for reading and understanding the contents of this policy.
8.3 You may be liable to disciplinary action if you fail to comply with the provisions of this policy.