Anti-Bribery and Corruption Policy - Foremost Furniture Limited

Foremost Furniture Limited – Anti-Bribery and Corruption Policy

Scope
This policy applies to all employees and directors of the company and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, the company (“associated persons”) within the UK and overseas.

The company is committed to the highest standards of ethical conduct and integrity in its business activities. As such, this policy outlines the company’s position on preventing and prohibiting bribery or corruption in accordance with the Bribery Act 2010.

The company will not tolerate any form of bribery or corruption and will take the necessary disciplinary action including dismissal for confirmed breaches of this Policy.

Definition of A Bribe
Under the Bribery Act 2010, a bribe is defined as:

“A financial or other type of advantage that is offered or requested with the intention of inducing or rewarding improper performance of a function or activity with the knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity”

The company prohibits you from offering, promising, giving, soliciting or accepting any bribe. The bribe might be cash, a gift or other inducement to, or from, any person or company, whether a public or government official, official of a state-controlled industry, political party or a private person or company, regardless of whether the employee or associated person is situated in the UK or overseas. The bribe might be made to ensure that a person or company improperly performs duties or functions (for example, by not acting impartially or in good faith or in accordance with their position of trust) to gain any commercial, contractual or regulatory advantage for the company in either obtaining or maintaining company business, or to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors, sub-contractors, agents, sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.

This prohibition also includes facilitation payments which are payments made to government officials for carrying out or speeding up routine procedures. They are more common overseas.

Employees and associated persons conducting business on behalf of the company outside the UK may be at greater risk of being exposed to bribery, corruption, or unethical business conduct than UK-based employees and so if this applies to you, then you owe a duty to the company to be extra vigilant when conducting international business.

Corporate Entertainment, Hospitality & Gifts
The company permits corporate entertainment, gifts, hospitality and promotional expenditure that is undertaken within the UK or overseas for the purposes of establishing or maintaining good business relationships to improve the image and reputation of the company or to present the company’s goods/services effectively. However; it must be demonstrated that the activity has been arranged in good faith and not offered, promised or accepted to secure an advantage for the company or to influence the impartiality of the recipient.

The company will only authorise reasonable, appropriate and proportionate entertainment and promotional expenditure in line with the above guidelines. You are required to submit requests for proposed hospitality and promotional expenditure well in advance of proposed dates to your Managing Director/Directors to gain authorisation for such expenditure. The company will approve business entertainment proposals only if they demonstrate a clear business objective, are appropriate for the nature of the business relationship and do not breach this Policy.

Any gifts, rewards or entertainment received from clients, public officials, suppliers or other business contacts should be reported immediately to your Managing Director/Directors. In certain circumstances, it may not be appropriate to retain such gifts and you may be instructed to return the gifts to the sender. As a rule, small tokens of appreciation, such as flowers or a bottle of wine may be retained by you with your Managing Director/Directors approval.

If you wish to provide gift(s) to suppliers, clients or other business contacts, prior written approval from your Managing Director/Directors is required, together with details of the intended recipients, reasons for the gift and business objective. These will be authorised only in limited circumstances. You must supply records and receipts, in accordance with the company’s expenses policy.

The company does not usually make donations to any political parties/charities. As such, you are not permitted to make any charitable and political donations to organisations on behalf of the company without the agreement of your Managing Director/Director.

Company Records
You are required to take particular care to ensure that all company records are accurately maintained in relation to any contracts or business activities, including financial invoices and all payment transactions with clients, suppliers and public officials.

Due diligence should be undertaken by employees and associated persons prior to entering into any contract, arrangement or relationship with a potential supplier of services, agent, consultant or representative and should be carried out in line with our internal company procedures.

You are required to keep accurate, detailed and up-to-date records of all corporate hospitality, entertainment or gifts accepted or offered.

Risk Management
The company has established a risk management process to prevent, detect and prohibit bribery or corruption which it will conduct at regular intervals. Where relevant, the assessment will identify high risk projects and employees or officers of the company who are in positions where they may be exposed to bribery or corruption.

The company will:

regularly communicate its anti-bribery & corruption measures to employees and associated persons and, if appropriate, will carry out training sessions regularly monitor “at risk” employees and associated persons;
regularly communicate with “at risk” employees and associated persons;
undertake extensive due diligence of third parties and associated persons; and
communicate its zero-tolerance approach to bribery or corruption to third parties, including actual and prospective customers, suppliers and joint-venture partners.

Reporting Suspected Bribery or Corruption
You are requested to assist the company and to remain vigilant in preventing, detecting and reporting bribery or other forms of corruption and are encouraged to report any concerns that you may have to the Managing Director/Directors of the company at the earliest possible opportunity.

Issues that should be reported include (this list is not exhaustive):

any suspected or actual attempts at bribery;
concerns that other employees or associated persons may be being bribed; or
concerns that other employees or associated persons may be bribing third parties, such as clients or government officials.
close family, personal or business ties that a prospective agent, representative or joint-venture partner may have with government or corporate officials, directors or employees;
a history of corruption in the country in which the business is being undertaken;
requests for cash payments;
requests for unusual payment arrangements, for example via a third party;
requests for reimbursements of unsubstantiated or unusual expenses; or
a lack of standard invoices and proper financial practices.

Any such reports will be thoroughly and promptly investigated by the company in the strictest confidence.

Employees or associated persons who report instances of bribery or other forms of corruption in good faith will be supported by the company. The company will ensure that the individual is not subjected to detrimental treatment as a consequence of their report. Any instances of detrimental treatment by a fellow employee because an employee has made a report will be treated as a disciplinary offence. An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, employees and associated persons should not agree to remain silent.

Consequences
The company will fully investigate any reports of alleged or suspected bribery or corruption. Employees suspected of bribery or corruption may be suspended from their duties while the investigation is being carried out.

The company will invoke its disciplinary procedures where any employee is suspected of bribery or corruption, and proven allegations may result in a finding of gross misconduct and summary dismissal. The company may terminate the contracts of any associated persons, including consultants or other workers who act for, or on behalf of, the company who are found to have breached this policy.

The company may also report any matter to the relevant authorities, including the police and will provide all necessary assistance to the relevant authorities in any subsequent prosecution.