Anti-Bribery and Anti-Corruption Policy

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

Policy Statement

ENCO Ltd is committed to conducting the highest standards of ethical conduct and integrity in its business activities in the UK and oversea. Every employee acting on ENCO’s behalf is responsible for maintaining our reputation and for conducting the company honestly and professionally.

Here at ENCO Ltd we take a zero-tolerance approach to bribery and corruption and are committed to acting fairly and with integrity in all our business dealings and relationships.

The purpose of this policy statement is to:

 – set out our responsibilities, and of those working or providing a service for us is observing and upholding our position on bribery and corruption.

– providing information and guidance on how we expect those working for us to conduct themselves and how to recognise and deal with bribery and corruption issues.

– how to raise concerns with us including any breaches of this policy statement.

What is Bribery?

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. An offence is committed when the bribe is coupled with an intention of inducing, a reward for or in anticipation for a person to improperly perform their function or if the request, agreement to accept or acceptance of the bribe itself constitutes or is believed to constitute the improper performance of an activity. Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively or through a third party. They must not bribe a foreign official anywhere in the world. They must not accept bribes in any degree and if they are uncertain of whether something is a bribe or a fit or act of hospitality, they must seek further advice.

Responsibilities

The prevention, detection and reporting of bribery and other forms of corruption is the responsibility of all those working for us, or supplying services to us, or under our control.

Gifts and Hospitality

ENCO Ltd permits normal and appropriate corporate entertainment, gifts, hospitality and promotional expenditure to or from third parties that undertake

  1. For the purpose of establishing and maintaining good business relationships
  2. To improve image and reputation of ENCO Ltd
  3. To present ENCO Ltd goods/services effectively

Provided that it is;

  1. In good faith
  2. Not offered, promised or accepted to secure advantage for its employees or associated persons or to influence the impartiality of the recipient

The giving or receiving of cooperate entertainment and hospitality of our employees should not exceed an approximate value of £100, without prior approval of an ENCO Ltd Executive committee member.

What is not acceptable?

There are many scenarios where there will be a breach of the Bribery Act 2010, however below are some non-exhaustive scenarios that we think is unacceptable for ENCO to do;

  1. Give, promise to give, or offer a payment, gift or hospitality to a third party with the exception or hope that a business advantage will be received
  2. Give, promise to give, or offer a payment, gift or hospitality to a government official, agent or representative to ‘facilitate’ or expedite a routine procedure
  3. Give, offer or promise to a foreign public official to induce that public official to obtain or retain business or an advantage in the conduct of business, request, agrees to receive or accept payment for a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them
  4. Request, agrees to receive or accept payment for a third party knowing or suspecting it is offered with the expectation that it will obtain a business advantage for them
  5. Accept a gift or hospitality for a third party knowing or suspecting that it is offered or provided with an expectation that a business advantage will be provided by ENCO in return
  6. Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy
  7. Engage in any activity that might lead to a breach of this policy

Facilitation Payments and Kickbacks

ENCO Ltd does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine government action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty of action

We do not accept kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

ENCO Ltd recognise that, despite our strict policy of facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their family’s personal security at risk. In these circumstances

  1. Keep any amount to a minimum
  2. Ask for a receipt, detailing the amount and reason for payment
  3. Create a record concerning the payment
  4. Report this incident to your line manager

Record Keeping

We and our service providers are expected to keep financial records and have appropriate internal controls in place which will evidence the business reason for giving ace/or receiving payments from/to third parties

Raising Concerns

If you believe this policy is being breached, or suspect it may have been breached, in any way please contact ENCO HR, Nichola Hull.

Jamie Moody

Managing Director

14th October 2019

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