Anti-Bribery and Corruption Policy and Procedure

This Anti-Bribery and Corruption Policy and Procedure (“the Anti-Bribery Policy”) forms part of Britannia Movers ethics Policy and represents our commitment to operating within appropriate ethical guidelines at all times.

When working for Britannia Movers employees, suppliers and commercial partners are agreeing to and are obliged to:-

• uphold this commitment;
• ensure you understand the requirements of Anti-Bribery Policy and the standards, instructions and associated compliance processes; and
• ensure that these are followed at all times.

Policy statement

Britannia Movers expects its employees to demonstrate honesty, integrity and fairness in all aspects of their business dealings and exercise appropriate standards of professionalism and ethical conduct throughout their day to day activities.  The Company expects the same approach to doing business from its business partners and suppliers.

Pursuant to this the Company will not tolerate bribery or corruption in any form and has a ‘zero tolerance’ approach to any breach of this policy. For the avoidance of doubt, the definitions are set out as follows:

Bribery: The receiving/offering/giving/providing/requesting/accepting of a financial or other advantage, in order to seek to  induce a person to give improper assistance in breach of their duty, or to otherwise influence someone with the underlying purpose of obtaining/retaining business, or an advantage in the course of business.  “Bribery” for this purpose includes so-called “facilitation” payments, defined as non-discretionary payments made to government or public officials to speed up routine administrative processes, even if such payments are nominal in amount.

Corruption: The misuse of entrusted power/breach of duty for personal gain.

Application

This means that Britannia Movers and its employees will never seek, accept or provide a bribe, facilitation payment, kickback or other improper payment and must also always ensure that they operate with appropriate transparency in all business dealings.

If a Britannia Movers employee is in any doubt as to whether something is appropriate ask yourself how your fellow employees would view your conduct, or how you would feel if your conduct featured within a public forum or media publication. If you are in any doubt as to whether something constitutes appropriate action, please refer the matter to your line manager or seek guidance from the Executive team or a legal specialist. If you are still uncomfortable or are concerned by the actions of others you can also use the Whistleblowing procedure as detailed in the Staff Handbook. There are also guidelines available online via the UK Governments own website: https://www.gov.uk/whistleblowing/how-to-blow-the-whistle

Policy

Britannia Movers (The Company) will take appropriate steps to ensure that:

1. The Company does not, directly or indirectly, offer, promise, give, accept or demand a bribe or other undue advantage (including excessive gifts and hospitality) in order to obtain or retain business, or gain any other improper advantage.
2. Does not offer, nor give in to demands, to make illicit or illegal payments to agents, public officials (at whatever level), or the employees of business partners or anybody else that it does business with.
3. Engages and remunerates agents and other third parties only for legitimate services and adopts appropriate transparency in its approach.
4. Promotes employee awareness of, and compliance with, company policies against bribery and corruption through appropriate communication of Company procedures (including disciplinary procedures) policies and training programmes on induction and subsequently on the continuation and development of the specific legislation.
5. Adopts management protocols that discourage bribery and corruption, and adopt financial and tax accounting and auditing practices that prevent the establishment of “off the books” secret accounts or the creation of documents which do not properly and fairly record the transactions to which they relate.
6. Does not make illegal or inappropriate contributions to candidates for public office or to political parties or to other political organisations.
7. Undertakes to raise awareness of the need to combat bribery and corruption with business partners by publication of this Policy and (where appropriate) makes relevant contractual provisions and supports initiatives designed to reduce the risk of bribery and corruption.