Anti-Bribery Policy

For Financial Year 2022/23

T Brown Group is committed to implementing and enforcing effective systems to counter bribery. Therefore it is the Company’s policy to conduct all aspects of its business in an honest and ethical manner at all times. The aim of this policy is to help the Company act in accordance with the Bribery Act 2012 maintain the highest possible standards of business practice and advise individuals of the companies ‘zero-tolerance’ to bribery.

This policy applies to all individuals working for the Company, including anyone providing services to the Company such as consultants, or contractors.

The Law:
Under UK law (UK Bribery Act 2012), bribery and corruption is punishable for individuals by up to ten years imprisonment. If the Company is found to have taken part in the corruption or lacks adequate procedures to prevent Bribery, it could face an unlimited fine and be excluded from tendering for Government contracts.

– Bribe is a financial or other advantage offered or given to anyone to persuade them to or reward them for performing their duties improperly or with the intention of influencing them in the performance of their duties.
– Hospitality is the practice of being hospitable. This includes the reception and entertainment of guests and visitors. This policy does not prohibit giving and receiving promotional gifts of low value or normal and appropriate hospitality.
– Kickbacks or facilitation payments are typically small payments made in return for a business favour or advantage.

Company Responsibilities:
The company will not:
– Make contributions of any kind with the purpose of gaining any commercial advantage.
– Provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a public official in the performance of their duties.
– Make, or accept, “kickbacks” of any kind

The company will:
– Keep appropriate internal records that will evidence the business reason for making any payments to third parties.
– Encourage employees to raise concerns about any issue or suspicion of malpractice at the earliest possible stage.
– See that anyone raising a concern about bribery will not suffer any detriment as a result, even if they turn out to be mistaken.

Employee Responsibilities:
It is the responsibility of all employees to prevent and report conduct which has taken place which you suspect is a bribe (or corrupt). Any such incidents can be reported to a Manager or by using the procedure set out in the company’s Whistle Blowing Policy.

Non Compliance:
– Staff: Failing to observe Company policy may lead to disciplinary action in accordance with the Company’s Disciplinary Policy.
– Visitors: In the event of a breach of the policy by other organisations, or individuals, the Company will take appropriate action.

Monitoring Policy:
The policy will be monitored on an on-going basis to ensure that it addresses issues effectively. The following will be monitored:

– That all individuals working for or on behalf of the Company are advised of the policy.
– Assessment of any reported incident or related occurrence.

Monitoring of the policy is essential to assess how effective the Company has been to establish control of its obligations.

Reviewing Policy:
This Policy was reviewed in April 2022 and will be reviewed on a yearly basis and, if necessary, revised in the light of legislative or organisational changes. Improvements will be made by learning from experience and the use of an established annual review.

Policy Amendments:
Should any amendments, revisions, or updates be made to this policy it is the responsibility of the Board of Directors to see that all relevant employees receive the amendments. Training should be considered.

The Anti-Bribery Policy has been validated by the Directors of T Brown Group