Anti-Bribery

Bribery and corruption are illegal in most countries where businesses operate. As a UK-registered company, our Business is subject to the Bribery Act 2010 (the Act). Therefore, we have a zero-tolerance policy towards bribery and corruption in all operations.

We are commited to:

• Acting professionally and reasonably.
• Acting with integrity in all its business dealings and relationships.
• Implementing and enforcing effective systems to counter bribery and corruption.

What does this policy cover?

This policy deals with the issue of bribery and corruption within the company, irrespective of where it takes place, whether in the UK or overseas. It outlines the steps each employee must take to prevent such conduct in compliance with relevant laws and the company's regulations. It is important to note that this policy is not part of any employment contract, and the company can change it at any time, at its sole discretion.

What are Bribery and Corruption

A bribe refers to any reward or inducement offered, promised, requested, or given to obtain an advantage in a commercial, contractual, regulatory, or personal setting. Typically, a bribe involves providing someone a financial or other benefit in exchange for their improper conduct or to reward them for it.

Bribes, in the form of financial or other advantages, may include:

• money (whether in the form of cash or cash equivalent);
• any form of gift;
• hospitality and entertainment;
• loans;
• services;
• preferential treatment;
• discounts;
• promises to provide financial or other advantages in the future.

For something to be considered a bribe and be subject to this Policy

• the timing of the bribe is irrelevant, and any payments made or advantages given after a relevant event are considered bribes;
• the payment made, or advantage given, can be given or received unknowingly; and
• it is also unnecessary for the bribed party to actually receive a benefit from the bribe.

Bribery includes:

• giving, offering or promising a bribe.
• requesting, receiving or agreeing to receive a bribe; or
• bribing a foreign public official (as defined in the Act).
• ‘Corruption’ is the misuse of power or office for private gain.

This means nobody should:

• offer or provide a bribe (e.g. any payment, gift, hospitality or other benefit) to reward the business advantage received or in the expectation that a business advantage will be received.
• accept a third party’s offer that they know or suspect to be made with the expectation that it will provide a business advantage (to the third party or anyone else).
• offer or provide a payment to a government official in any country (in the UK or abroad) to facilitate or speed up a necessary or routine procedure.
• fail to prevent bribery and corruption from occurring.

No one should face intimidation, threats, or retaliation for refusing or reporting bribery attempts.

For the purposes of this Policy, it does not matter whether:

• bribery and corruption occur in the UK or abroad. Any act of bribery or corruption committed outside of the UK may be prosecuted in the UK; or
• the act of bribery and corruption is committed directly or indirectly.

Who can be involved in Bribery and Corruption?

Bribery and corruption can be committed by:

• any worker of the Business, irrespective of seniority, tenure and working hours, including all employees, directors and officers, consultants and contractors, temporary and agency workers, trainees, casual and fixed-term staff, apprentices, interns and any volunteers
• anyone otherwise authorised to act on the behalf of staff;
• the Business’ representatives and any other third parties who act on the Business’ behalf;
• the Business’ clients or customers (e.g. a customer may attempt to induce someone working for the Business to give that customer more favourable treatment).

This Policy and the rules contained within it to those listed in paragraph 13 above

In what circumstances can Bribery and Corruption occur?

• Bribery and corruption can occur in the public and private sectors
• Typically, the person receiving the bribe can influence the progress of or be aware of relevant business due to their position. The person receiving the bribe will often, but only sometimes, be a government or public official.

Who is responsible for this Policy?

• The Board of Directors has overall responsibility for this Policy.
• The Operations Manager has been appointed as the person with primary and day-to-day operational responsibility forimplementing this, Policy. They will also monitor the Policy's use andeffectiveness and ensure that it is adhered to. 
• Management personnel at all levels are responsible for ensuring those reporting to them is made aware of and understand this Policy and are given adequate and regulartraining on it.

Gifts and hospitality

• All Staff are forbidden from soliciting gifts or hospitality during their work for the business.
• All Staff are forbidden from offering or receiving gifts or hospitality that are unduly lavish, extravagant or otherwise inappropriate from any person or organisation that has or may have influence over the Business’ business.
• Continually improve and reduce environmental impacts
• Incorporate environmental factors into business decisions
• Increase employee awarenessand training

The following is a non-exhaustive list of gifts and hospitality the business deems inappropriate:

• Hospitality valued at more than £0.00.
• personal or corporate gifts with a value greater than £0.00
• Any gifts that include cash or cash equivalents (including, but not limited to, vouchers)
• Any hospitality or gifts given or received in secret
• Any hospitality or gifts received in an individual's name rather than the business' name

If you have any questions about gifts and hospitality, contact the Operations Manager at csteam@theomegagroup.co.uk.

Keeping records

• As transparency is crucial and false ormisleading records could be damaging to the Business, it is essential that theBusiness keeps a full and accurate record of all financial dealings. Underrelevant money laundering regulations, the Business’ accountants and lawyersare required to report anything that seems irregular
• Staff must declare and properly record in writing all hospitality and gifts received or given. In relation to any hospitality, gifts or payments tothird parties (including suppliers and customers), Staff must: 
• submit expense claims in accordance with the Business’ Expense Policy available from the HR Department; and
• record in writing the reason for the expenditure.
• All accounts, invoices, purchase orders, credit notes and other records relating to third parties must be accurately and fully prepared in accordance with the business’ procedures, practices, and requirements.

Reporting issues related to Bribery and Corruption

All Staff have a responsibility to comply with this Policy and prevent bribery and corruption. Staff who:

• witness or otherwise discover anything corruptor otherwise improper taking place
• are offered a bribe
• are asked to offer a bribe; or
• suspect or discover that any bribery orcorruption has taken place or may take place
• must report this in accordance with the business’ Whistleblowing Policy, available from the HR Department, as soon as possible. Staff can do this anonymously. As Staff must report issues related to bribery and corruption as soon as possible,any delays will need to be explained.

Consequences of non-compliance

• The business takes compliance with this Policy very seriously and failure to comply with this Policy puts both Staff and the business at significant risk.
• Staff who fail to comply with this Policy may commit a criminal offence and thecriminal law relating to bribery and corruption carries several penalties.
• Due to the importance of this Policy, failure to comply with any of its procedures and requirements may result in disciplinary action and/or dismissal for gross misconduct. Any non-Staff who breach this Policy may have their contract terminated with immediate effect.
• If you have any questions or concerns about anything in this Policy, please contact the Operations Manager at csteam@theomegagroup.co.uk.