Anti-Bribery and Anti-Slavery Policy
1. About this policy
1.1.
We conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery, corruption, modern slavery and human trafficking, and we are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
1.2.
This policy sets out our position and responsibilities in two areas: Part A — anti-bribery and corruption; and Part B — anti-slavery and human trafficking. It also explains how to report concerns (clause 8) and who to contact (clause 9).
1.3.
We uphold all applicable laws in every jurisdiction in which we operate, including, in the UK, the Bribery Act 2010 (which applies to our conduct both in the UK and abroad) and the Modern Slavery Act 2015.
1.4.
This policy applies to all individuals working for us or on our behalf in any capacity, including employees at all levels, directors, officers, consultants, contractors, and casual and agency staff (referred to as “you”).
1.5.
We also expect our suppliers, contractors and business partners to uphold the standards in this policy within their own operations and supply chains.
1.6.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We may terminate our relationship with any other individual or organisation that breaches this policy, with immediate effect. Bribery, corruption, modern slavery and human trafficking are also criminal offences that carry serious penalties, including imprisonment for individuals and unlimited fines for organisations, and you may commit a criminal offence if you fail to comply with this policy.
Part A — Anti-Bribery and Corruption
2. What is bribery
2.1.
A bribe is a financial or other inducement or reward offered, promised or provided to gain a commercial, contractual, regulatory or personal advantage improperly, or to reward improper conduct. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract, or any other advantage or benefit.
2.2.
Bribery includes offering, promising, giving, requesting, agreeing to receive, or accepting a bribe. It is not necessary for the improper act to actually take place.
2.3.
All forms of bribery are strictly prohibited. If you are unsure whether something constitutes bribery, raise it with the person named in clause 9 before proceeding.
2.4.
Specifically, you must not:
give, promise or offer any payment, gift, hospitality or other benefit in the expectation, or with the effect, that a business advantage will be received or rewarded improperly;
accept, or agree to accept, any payment or benefit from a third party that you know or suspect is offered with the expectation that we will provide a business advantage in return;
offer, give or accept any payment or benefit to or from a public official to influence them in their official capacity;
retaliate against, or threaten, any person who has refused to commit a bribery offence or who has raised a concern under this policy; or
engage in any activity that might reasonably lead to a breach of this policy.
3. Corruption
3.1.
Corruption is the misuse of office or power for private gain. Bribery is a form of corruption.
4. Facilitation payments and kickbacks
4.1.
We do not make, and will not accept, facilitation payments (small unofficial payments made to secure or speed up a routine government action) or kickbacks (a return of a sum already paid, or due to be paid, as a reward for awarding or retaining business).
4.2.
If you are asked to make a facilitation payment, refuse and report it in accordance with clause 8. The only exception is where your personal safety or liberty is under threat; in that case, make the payment, keep any record you safely can, and report it as soon as possible.
5. Gifts and hospitality
5.1.
This policy does not prohibit normal and appropriate gifts and hospitality (given or received) to or from third parties. Gifts and hospitality are acceptable only if they:
are given in the name of the organisation, not an individual;
do not include cash or a cash equivalent (such as vouchers);
are of an appropriate type and value, and given at an appropriate time;
are not unduly lavish or extravagant; and
are given openly, not secretly.
5.2.
Different parts of the world have different social and cultural customs, and in some cultures refusing or failing to offer a gift may be considered impolite. If you are uncertain whether a gift or hospitality is appropriate, discuss it with the person named in clause 9 before giving or accepting it.
Part B — Anti-Slavery and Human Trafficking
6. Our commitment and principles
6.1.
Modern slavery is a term used to describe holding a person in slavery or servitude, requiring them to perform forced or compulsory labour, or human trafficking (arranging or facilitating the travel of another person with a view to their exploitation). These crimes exist across the world, including in the UK, and can occur in any sector.
6.2.
We will take action to identify, prevent and mitigate modern slavery in our operations and supply chains. We will not knowingly support or deal with any business involved in modern slavery or human trafficking.
6.3.
As part of our efforts to monitor and reduce the risk of modern slavery in our supply chains, we operate the following due diligence measures:
conducting risk assessments to identify the parts of our business and supply chain most at risk;
engaging with our suppliers to communicate this policy and understand the measures they take;
building, where possible, long-standing relationships with reputable suppliers and making our expectations clear; and
for international supply chains, preferring a UK point of contact and expecting suppliers to maintain their own anti-slavery policies and processes.
6.4.
We provide training to relevant staff to ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains.
6.5.
Our commitment to addressing modern slavery is communicated to suppliers, contractors and business partners at the outset of our relationship and reinforced as appropriate.
7. Modern slavery — your responsibilities
7.1.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of everyone working for us or under our control. You must follow this policy at all times and avoid any activity that might lead to, or suggest, a breach of it.
7.2.
If you are unsure whether a particular act, the treatment of workers, or working conditions within any tier of our supply chain amounts to any form of modern slavery, raise it with your manager in the first instance, or with the person named in clause 9.
8. Reporting concerns and record-keeping
8.1.
You must declare and keep a written record of all gifts and hospitality given or received, and submit all related expense claims with the reason for the expenditure. We maintain a gifts and hospitality register; please notify the person named in clause 9 of any gifts received. We do not record low-value promotional items (such as branded pens and notepads).
8.2.
You are expected to follow this policy at all times and to avoid any activity that might lead to, or suggest, a breach of it.
8.3.
You must report promptly if you know or suspect that: bribery or corruption has occurred or may occur; you are offered a bribe or asked to give one; or modern slavery or human trafficking is occurring, or may be occurring, in our business or supply chains.
8.4.
You can raise a concern with the person named in clause 9, or with your manager. Concerns may be raised in confidence, and we will not tolerate any retaliation against anyone who reports a genuine concern in good faith.
9. Questions and contact
9.1.
If you have any questions about this policy, or wish to report a concern, please contact Christopher Batts at hello@setyl.com.
