Introduction
IPS appreciates our responsibility for setting an example in ethical business practice. In response to the UK Bribery Act we have made every effort to review our practices, identify potential risks and raise awareness of the act amongst our employees. Our first business principle deals with ‘integrity in corporate conduct’ which commits us to implement anti-corruption policies and procedures. Ensuring openness and transparency commits us to never engage in bribery, any form of unethical inducement or payment including facilitation payments and ‘kickbacks’.
The UK Bribery Act 2010 and the US Foreign Corrupt Practices Act 1977 create offences and penalties for bribery and corruption.
This policy sets out the responsibilities of IPS employees in preventing bribery and corruption and how we will implement adequate procedures to do so.
Definition
Bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favour or a financial or other advantage from another to influence a business outcome improperly, or to induce or reward improper conduct.
Corruption is the abuse of public or private office for personal gain.
“Improper performance” happens when a person fails to act in good faith, impartially or in accordance with a position of trust.
Scope
Under the UK Bribery Act 2010, IPS is required to put procedures in place to prevent bribery by any individual or organisation that performs services for or on behalf of IPS. Consequently, this policy applies to every employee, contractor and director.
Contractors or suppliers who are working on our behalf in our name, through outsourcing of services, processes or any business activity, will be required to act consistently with this policy when acting on our behalf. Independent contractors and suppliers will be made aware of this policy as it applies to our people in their dealing with them.
Policy
IPS does not tolerate any form of bribery or corruption.
You must not offer, pay, make, seek or accept a personal payment, gift or favour in return for favourable treatment or to gain any business advantage. You must follow the anti-bribery and corruption laws to which you and IPS are subject, remembering that UK and US anti-bribery and corruption laws apply wherever you are operating.
You are liable to disciplinary action, dismissal, legal proceedings and possibly imprisonment if you are involved in bribery and corruption.
You must ensure all employees understand that bribery and corruption is unacceptable.
You must comply with IPS procedures for the prevention of bribery and corruption.
Procedures
Anti-bribery and corruption is a business priority. IPS will regularly identify bribery and corruption risk in its business and implement adequate risk-based procedures aimed at preventing bribery and corruption occurring.
To meet our commitments we will:-
- Communication- We will communicate this policy and relevant guidance to all employees as well as our suppliers and contractors.
- Books and records- We will maintain adequate books and records which properly and fairly document all financial transactions. We will maintain written evidence to record our compliance with this policy.
- Business relationships- We will ensure that our business partners- including contractors, suppliers and agents are fit to do business with.
- Supply chain- We will address bribery and corruption risk in our supply chain by ensuring that payments made for goods and services are reasonable.
- Gifts and hospitality- We will address the risks created by gifts and hospitality through the implementation of our internal policies.
Responsibilities
The managing director of IPS is responsible for our anti-bribery and corruption efforts and to ensure compliance with this policy. However, all employees have an obligation to act with integrity and to ensure that they understand and comply with the policy.
Reporting actual or potential violations and seeking guidance
You must report actual, potential, or suspected corruption within IPS or by any individual or company with whom IPS does business with. Failure to do so may result in liability for IPS and for you personally.
You must report any request for an improper payment, or any indication that a person might be making corrupt payments or that a person has an intention or plan to violate this policy.
If any instance of bribery or corruption is identified, an investigation will take place.
You can also seek advice on anti-bribery and corruption issues or to make suggestions for how IPS can improve its anti-bribery and corruption policy and procedures.
