Business Ethics & Anti-Bribery Policy
The Myers Group are committed to operating in an ethical manner and will ensure compliance to the Bribery Act 2010. The Group has developed this policy as part of our commitment to this and expect every individual to always act in an honest and professional manner.
Under the Bribery Act 2010, a bribe is a ‘financial or other advantage’ offered, promised or given to induce a person to perform a relevant function or activity improperly, or to reward them for doing so. The Act makes it a criminal offence to:
• offer, promise or give a bribe.
• request, agree to receive or accept a bribe.
• bribe a foreign public official to obtain or retain business or a business advantage.
• (by an organisation) fail to prevent bribery by those acting on its behalf (‘associated persons’) to obtain or retain business or a business advantage for the organisation.
• Small payments made to government officials or others to make something happen, or happen sooner, (commonly called facilitation payments) are likely to be bribes and unlawful under the Act.
Under the Bribery Act, individuals can be prosecuted for accepting bribes or offering bribes. In addition, the Group can be prosecuted for failing to prevent bribery committed to obtain or retain business or a business advantage for the Group by an employee.
The Group does not tolerate any form of bribery, whether direct or indirect, by its employees, agents, consultants, contractors, suppliers, subsidiaries, joint venture partners and any other third parties performing services for or on behalf of the Group.
Individuals should note that bribery is a criminal offence in the UK that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for the organisation on behalf of which the bribery offence is committed.
As part of its anti-bribery measures, the Group is committed to proportionate, reasonable and bona-fide hospitality and promotional expenditure. The frequency and scale of any hospitality accepted by a third party should in general not be significantly greater than they or the Group would be likely to provide in return.
While there is no requirement to report one-off very small token gifts (Under £50) employees should seek advice from their line manager if:
• they are offered or offering gifts of higher value; or
• they offer/receive a succession of small gifts within a short period of time; or otherwise have any concern that there is an intention to influence them to change their behavior or act improperly.
Depending on the circumstances, the appropriate action may be to:
• accept and keep the gift or hospitality;
• accept the gift but raffle it among colleagues and donate the money to charity;
• accept the gift but share it with colleagues;
• politely decline the gift or hospitality;
Any expenditure which does not comply with this principle must be authorised in advance in writing by email by the appropriate line manager. It is a personal responsibility of both the individual requesting authorisation by email and the line manager giving his response to that request to retain a copy of all such email correspondence as all individuals may be called by the Group to produce evidence of any such requests and the responses given at any time.
Any Employee accepting/offering unauthorised gifts will subject to disciplinary action as set out in the company handbook.