Bribery

We prohibit 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 firm’s behalf; 
• in order to gain any commercial, contractual, or regulatory advantage for the firm in any way which is unethical or to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
• for any form of money laundering purposes.

This policy is not intended to prohibit the following practices provided they are appropriate, proportionate and are properly recorded:

• normal hospitality
• fast tracking a process which is available to all on the payment of a fee; and/or
• providing resources to assist a person or body to make a decision more efficiently, provided that it is for this purpose only.

We 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 which may ultimately result in their dismissal.

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, then you have a duty to report this. 

Any such incidents should be reported to the Chairman, Mike Jackson, immediately.

We endeavor to meet the anti-bribery standards set out in ISO 37001.