Anti Bribery; Corruption and Unfair Competition

Acts of bribery or corruption are designed to influence an individual in the performance of their duty and incline them to act in a way that a reasonable person would consider to be dishonest in the circumstances.

Bribery can be defined as offering, promising or giving a financial (or other) advantage to another person with the intention of inducing or rewarding that person to act or for having acted in a way which a reasonable person would consider improper in the circumstances.  Corruption is any form of abuse of entrusted power for private gain and may include, but is not limited to, bribery.

Bribes are not always a matter of handing over cash.  Gifts, hospitality and entertainment can be bribes if they are intended to influence a decision.

The Bribery Act 2010 came into force on 1 July 2011.  Under that Act, bribery by individuals is punishable by up to ten years’ imprisonment and/or an unlimited fine.  If Grommets Ltd are found to have taken part in the bribery or is found to lack adequate procedures to prevent bribery, it too could also face an unlimited fine.

A conviction for a bribery or corruption related offence would have severe reputational and/or financial consequences for Grommets

 Grommets Ltd will not tolerate bribery or corruption in any form.

Grommets Ltd 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 Grommets Ltd behalf.
• to gain any commercial, contractual, or regulatory advantage for Grommets Ltd in any way which is unethical or to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

This policy is not intended to prohibit normal hospitality, if it is appropriate, proportionate and are properly recorded.

It may not always be a simple matter to determine whether a possible course of action is appropriate.  If you are in any doubt as to whether a possible act might be in breach of this policy or the law, the matter should be referred to the Managing Director.

Grommets Ltd 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.

Bribery can be a risk in many areas of Grommets Ltd.  Below are the key areas you should be aware of in particular:

Excessive gifts, entertainment and hospitality:  can be used to exert improper influence on decision makers.

Facilitation payments: are used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer has an entitlement as of right.  Grommets will not tolerate or excuse such payments being made.

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 Grommets Ltd may be held responsible: can include a range of people i.e. agents, contractors and consultants, acting on Grommets Ltd behalf.  Appropriate due diligence should be undertaken before a third party is engaged.  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.

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.

The prevention, detection and reporting of bribery or corruption is the responsibility of all employees throughout Grommets Ltd.  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.