The following is a summarised version of Rendeavour’s anti-corruption and bribery policy. To request the full version, please email firstname.lastname@example.org
This anti-corruption and bribery policy applies to Rendeavour (the “Company”) and its subsidiaries and affiliates (collectively, the “Group”).
It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships anywhere we operate, and to implementing and enforcing effective systems to counter bribery and corruption.
We will uphold all laws relevant to countering bribery and corruption in all of the jurisdictions we operate. For avoidance of doubt, we shall uphold the United Kingdom Bribery Act 2010 and the United States Foreign Corrupt Practices Act, both of which have extra-territorial application and therefore can apply to activities all over the world, including the jurisdictions in which we operate.
It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by imprisonment and/or a fine. As an employer, if we fail to prevent bribery, we can face an unlimited fine, damage to our reputation, and exclusion from tendering for public contracts. We therefore take our legal responsibilities very seriously.
To address these risks we:
Have published a public statement of the Company’s zero tolerance to corruption and bribery, both internally and externally, via the website and by internal dissemination;
Shall maintain a Compliance Officer (who shall report to the Board) or Compliance Committee (of the Board), to monitor anti-corruption and bribery matters and policies—the Compliance Officer/Committee shall report directly to the Company’s Board; and
Shall conduct interactive bi-annual anti-corruption and bribery training sessions for all employees;
Shall conduct an annual comprehensive Company/Group-wide risk assessment;
Shall review anti-corruption and bribery policies and procedures, especially taking into consideration corporate hospitality and donations;
Shall conduct due diligence on all joint ventures or public private partnership partners, especially third parties in high risk jurisdictions or sectors;
Who must comply with this policy?
This policy applies to all persons working (a) for the Group and (b) on the Group’s behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.
What our workers must not do
It is not acceptable for our staff or agents (or someone on their behalf) to:
give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;
accept a payment, gift or hospitality from a third party, that the worker knows or suspects is offered with the expectation that it we will provide a business advantage for them, or anyone else in return;
accept hospitality from a third party that is unduly lavish or extravagant under the circumstances;
offer or accept a gift to or from government officials or representatives, or politicians or political parties, without the prior approval of the Compliance Officer/Committee;
threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
engage in any other activity that might lead to a breach of this policy.
Facilitation payments and kickbacks
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.
Facilitation payments, also known as “back-handers” or “grease payments”, are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official).
Kickbacks are typically payments made in return for a business favour or advantage.
All our workers must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If anyone is asked to make a payment on our behalf, they should always be mindful of what the payment is for, and whether the amount requested is proportionate to the goods or services provided. Our workers should always ask for a receipt which details the reason for the payment. If any of our workers have any suspicions, concerns or queries regarding a payment, they should raise these with the Compliance Officer/Committee.
Gifts, hospitality and expenses
This policy allows reasonable and appropriate hospitality or entertainment, given to or received from third parties, for the purposes of:
establishing or maintaining good business relationships;
improving or maintaining our image or reputation; or
marketing or presenting our products and/or services effectively.
The giving and accepting of gifts is allowed if the following requirements are met:
it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
it is given in our name after receiving all required internal approvals, not in any of our workers’ names;
it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in a number of countries, it is customary for small gifts to be given at Christmas;
it is given openly, not secretly; and
it complies with any applicable local law.
Promotional gifts of low value such as branded desk items to or from existing customers, suppliers and business partners will usually be acceptable.
Reimbursing a third party’s expenses, or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable.
We acknowledge that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in ALL the circumstances the gift, hospitality or payment is reasonable and justifiable (i.e., would it be an offence in the U.K.?—if so, it is not acceptable under this policy). The intention behind the activity should always be carefully considered.
We do not make contributions to political parties.
We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the Compliance Officer/Committee.
Our workers’ responsibilities
Our workers must ensure that they read, understand and comply with this policy, and undertake to so comply by signing a copy of this document and returning it to the Company.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Our workers must notify the Compliance Officer/Committee, or any member of the Board, as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers a worker something to gain a business advantage with us, or indicates to the worker that a gift or payment is required to secure their business.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with our workers if they breach this policy.
We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
Our workers must declare and keep a written record of all hospitality or gifts given or received, which will be subject to managerial review.
Our workers must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept ‘off-book’ to facilitate or conceal improper payments.
How to raise a concern
Workers who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If a worker believes that they have suffered any such treatment, they should inform the Compliance Officer/Committee immediately.
Training and communication
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Compliance Officer/Committee has primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
Monitoring and review
The Compliance Officer/Committee will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.
All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.
Workers are invited to comment on this policy and suggest ways in which it might be improved.