Appendix 11 - Anti-Bribery
Tracklements is committed to the prevention of bribery by those employed and associated with it and is committed to carrying out business fairly, honestly and openly, with zero-tolerance towards bribery.
You are not allowed to offer, promise, give, or request, agree to receive or receive any financial or other advantage to another person or business with the intention of gaining an improper financial or other advantage. All employees have a responsibility to prevent, detect and report all instances of bribery.
In your employment with Tracklements you should never offer a gift or hospitality to a customer, supplier or other person with the intention of gaining a business advantage.
From time to time, customers, suppliers or other persons might offer a gift to you. This could be a small item, or something of considerable value. All gifts, however small, must be reported to your manager and recorded. All gifts received will be placed in a prize pot for games at the festive event at the end of each year.
From time to time, customers, suppliers or other persons might invite you to a hospitality event. All such invitations must be reported to your manager. Permission must be given by your manager before you accept any invitation.
The Company occasionally runs hospitality events, primarily aimed at thanking customers and suppliers for their custom and loyalty. You must not organise any additional hospitality event without seeking authority your manager.
Your manager, or a director, will authorise all expense claims from all employees and will check and sign all expense claims against receipts.
Any items of expenditure that give rise to concern will be fully investigated.
If you are concerned you are potentially being bribed, you should report this matter to your manager immediately.
No donations should be made to charities, political parties or other organisations with the intention of gaining a business advantage.
Acts of bribery and/or corruption will always be taken seriously and has severe consequences for you and Tracklements. You have a duty to disclose any concerns about bribery (or any other unlawful activity) whether in relation to other employees, contractors or yourself. You should report your concerns in confidence, to your Manager as soon as practicable.
If you are found to have accepted or given any bribe, this may result in disciplinary action up to and including dismissal. This may also lead to criminal investigation and potential prison sentence and fine for those found guilty of bribery in addition to potential fines for Tracklements