Anti Bribery Policy

UK Bailiffs Anti Bribery and Corruption Policy



The Bribery Act 2010 came into force in the UK on 1 July 2011, and not only makes bribery and corruption illegal, but also holds UK companies liable for failing to implement adequate procedures to prevent such acts by those working for the company or on its behalf, no matter where in the world the act takes place.

Policies:

1. This anti-bribery policy exists to set out the responsibilities of UK Bailiff Services and those who work for us regarding observing and upholding our zero-tolerance position on bribery and corruption
2. UK Bailiff will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010(“the Act”) , in regards to our conduct both at home and abroad..
3. UK Bailiff Services has a zero-tolerance policy to bribery and corruption. We will never pay, promise, offer, make, seek or accept either directly or through a third party, a bribe or consideration to obtain new business, retain existing business or secure any business advantage or financial advantage..
4. We require all employees and contractors to comply fully with all applicable anti-bribery legislation including the UK Bribery Act 2010.
5. This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.
6. In law, bribery and corrupt behaviour can be committed by: an employee or director; any person acting on behalf of UK Bailiff Services; individuals and organisations where they authorise someone else to carry out these acts.
7. UK Bailiff Services prohibits the offering, giving, solicitation or the acceptance of any bribe, whether this be cash or otherwise:
8. to or from any person or company, whether a private individual or company wherever situated;
9. by any individual employee, agent or other associated person or company acting on UK Bailiff Services behalf;
10. in the form of a gift or entertainment provided to the decision maker’s spouse or other members of their family;
11. in order to gain any commercial, contractual or regulatory advantage for UK Bailiff Services in a way that is unethical; or
12. in order to gain any personal advantage, monetary or otherwise, for the individual or anyone connected with the individual.
13. Facilitation payments will not be accepted, even where it is a recognised way of doing business.

Directors, employees, contractors and agents duties

All employees and contractors must;

• act with integrity and carry out our business in a fair, honest and open way;
• comply with UK Bailiff Services anti bribery and corruption policy;
• apply appropriate due diligence procedures in the selection of suppliers, business partners or agents to reduce any bribery risk and take steps to ensure the suppliers etc are aware of the requirements of the Act;
• report any instance to UK Bailiff Services where they are offered a financial or other advantage which may constitute a bribe or where they think they have been offered or provided hospitality or a gift.
• report any instances to UK Bailiff Services where they are aware that a colleague or representative of UK Bailiff Services has received a financial or other advantage that has not been reported as required under this policy;
• decline to do business with others who do not accept our principles and policies and who may harm UK Bailiff Services reputation;
• not make use of their position in the company to further their private interests or those of others, including their family members.

Steps taken to prevent bribery

UK Bailiff Services takes the following steps to assist in the prevention of bribery and corruption:

1. Risk assessment.
2. Accurate accounting and record-keeping
3. Effective auditing and internal control

Once bribery and corruption risks have been identified and highlighted via the risk assessment process, procedures can be developed within our comprehensive control systems to help mitigate these risks on an ongoing basis.

Definitions

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.  

A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.  

Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from UK Bailiff Services

January 22 2019