ANTI BRIBERY POLICY
The purpose of this document is to provide a policy statement that minimizes the potential risks of jeopardizing a client relationship as a result of an act of bribery causing a conflict of interest between clients and/or potential clients.
To ensure the policy is upheld it should be noted that when preparing for prospective assignments or dealing with clients directly that the integrity of the company is upheld and that Stripout London Ltd (SL) will not tolerate any prohibition of the offer, gift or acceptance of bribes to ensure there is no conflict of interest.
In relation to the Bribery Act 2010 CL take their responsibilities seriously to ensure that any employee is fully informed of this policy and their responsibility either as an employee, contractor or agent of the company commit upholding the required actions.
SL is committed to this policy and unless an act occurs will take no further action. SL has agreed that the potential for such an action will be included in their business and financial risk management procedures.
It has been identified that there are sufficient existing controls in place in the company’s expenditure and accounting systems, commercial or agent contracts carried out by the management in charge of the day to day business to negate the need for further policy procedures.
It is essential to know who you are dealing with to protect the organisation from taking on or dealing with people who might be less than trustworthy. Therefore, where this is considered an issue then a set procedure/contract should be in use to ensure due diligence checks before engaging others to represent you in business dealings or carrying out work on your behalf. Where you think the risks are sufficiently high this may take the form of requesting CV’s, financial accounts and other references.
This policy will be issued and communicated to all partners, employees, contractors and shared with clients on their request.
Monitoring & Review
All procedures will be monitored and updated alongside all other documentation.
The following are some of the examples and not exhaustive to the prevention of bribery causing a conflict of interest and actions to be taken where appropriate:
Gifts, hospitality or expenses that may influence the outcome of business transactions
Provide guidance on political and charitable donations including to political parties that are directly linked to obtaining new business or gaining a business advantage
To ensure that any donations made in good faith are publicly disclosed
Note that the following are not considered acts of bribery:
Providing genuine business hospitality
Carrying out proportionate and reasonable promotional activities
Any employee found to have offered or excepted a bribe will be investigated which could lead to dismissal for misconduct
SL requires their employees or any others identified to sign this policy statement as applicable as acknowledgement of their commitment and understanding.