Our business dealings and relationships are based on professionalism, fairness and integrity. This policy offers examples of behaviours that would constitute bribery and corruption, which Search Laboratory adopts a zero-tolerance approach to. It also sets out Search Laboratory’s policies regarding the giving and receiving of gifts and hospitality, and the procedure for raising concerns if you believe there has been a breach of this policy.
This policy applies to all Search Laboratory employees, but also anyone working on Search Laboratory’s behalf, including agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
A bribe is a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit. Bribery includes offering, promising, giving, accepting or seeking a bribe.
All forms of bribery are strictly prohibited. If you’re unsure whether a particular act would constitute bribery, you can speak in confidence with HR or a Director.
Specifically, staff must not:
You are not prohibited from giving or accepting reasonable and appropriate gifts or hospitality for legitimate purposes, such as: building relationships, maintaining Search Laboratory’s image or reputation, or marketing Search Laboratory’s products and services. Extravagant gifts or hospitality will not be appropriate, or if it could be seen as an inducement or reward for preferential treatment (for example, during contractual negotiations or a tender process). Specific guidance on the giving or receiving of gifts or hospitability is set out below.
Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners without Director approval.
All gifts or hospitality should be recorded by the individual via the Gifts and Hospitality log which can be found on the intranet.
All expenses claims relating to hospitality, gifts or payments to third parties should be submitted in accordance with the Expenses Policy.
All accounts, invoices, and other records relating to dealings with third parties, including suppliers and customers, should be prepared with strict accuracy and completeness, and accounts must not be kept “off-book” to facilitate or conceal improper payments.
If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breaches of this policy has occurred or may occur, you must report it in accordance with the Whistleblowing Policy as soon as possible. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.