Anti-Bribery and Corruption Policy

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.

What is bribery?

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:

• Give or offer any payment, gift, hospitality or other benefits in the expectation that a business advantage will be received in return, or to reward any business received
• Accept any offer from a third party that you know, or suspect is made with the expectation that Search Laboratory will provide a business advantage for them or anyone else
• Give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure
• Threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption

Examples include:

• Offering a potential client tickets to a major sporting event, but only if they agree to do business with Search Laboratory
• Offering a friend who works at a competitor agency a lavish meal out, but only if they share information about their client, who we’re about to pitch to
• A client sends a bottle of champagne, but makes it clear they expect work to be completed on their account over the weekend
• A supplier makes it clear they expect a staff member to use their influence at Search Laboratory, in return for their nephew being offered a job with them.

Gifts and hospitality

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.

Giving of gifts/ hospitality:

• Gifts and hospitality must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift or hospitality e.g. in the UK it is customary for small gifts to be given at Christmas;
• Gifts must not include cash or cash equivalent (such as vouchers);
• Gifts must not be given in secret;
• Gifts must be given in Search Laboratory’s name, not your name;
• Any spend on client entertaining which is in excess of £40 per head must be approved by a Director.

Receiving of gifts/ hospitality

• Any gifts or hospitality received by you or offered to you should be reported to a Director and should not be accepted without Director approval;
• Unless a Director has given separate authorisation otherwise, all gifts which are accepted will be entered into a staff raffle.

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.

Record keeping

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.

Raising a concern

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.