1 About this Policy
1.1 Introduction
This Policy outlines Sonin’s zero tolerance to bribery and corruption and outlines our commitment to acting professionally, fairly and with integrity in our business dealings and relationships, implementing and enforcing effective systems to counter bribery.
1.2 General Principles
This Policy has been written in accordance with UK Government legislation.
2 Scope
This Policy applies to Sonin and our employees regardless of location or nationality.
The zero tolerance to bribery extends to all business dealings and transactions in all countries in which Sonin may operate.
Sonin and its Managers expect their clients, business partners and contractors to adopt effective policies to counter bribery and corruption in their own dealings.
2.1 Definition of Bribery and Corruption
Bribery is the offering, promising, giving, accepting or soliciting of a financial or other advantage. This may be on an undisclosed or secret basis or openly and transparently. This offer may be an inducement or reward for an action which is illegal, improper or represents a breach of trust. Corruption is the type of relationship brought about by bribery. Bribery is illegal under UK Government Legislation.
3 Company Policy and Procedures
The company Policy and Procedures are designed to counter bribery and corruption and may include:
- The payment of a bribe or facilitation of a payment for favours or preferential treatment;
- Any act of bribery or corruption which may lead to criminal penalties as well as the termination of the Company’s business relationship with any party committing such an act;
- Any form of ‘facilitation’ ‘kickbacks or ‘grease’ payments, either offered or agreed directly or indirectly, by the Company or any third party on the Company’s behalf;
- Political donations or contributions that may be offered or made in an attempt to influence any political decision or gain an unfair advantage.
This is not an exhaustive list.
Negotiations, agreements, provisions and communications with third parties should reflect the Company’s zero tolerance to bribery.
Any arrangements or activities which give rise to a concern of improper dealing, will always be fully investigated under the relevant company policies including this policy and the Disciplinary Policy.
Sonin commits to train relevant staff to ensure they fully understand the definition and risks of bribery and corruption.
It is important to ensure that gifts, hospitality, charitable donations, sponsorship, entertainment and expenses are in accordance with this policy. They must be compliant with local and UK Legislation and must not be excessive in value and frequency, nor leave the recipient in a position of obligation. They must be agreed by the Managing Director, documented and recorded in line with company procedures.
Sonin supports any staff member or third party who may raise concerns about any issue or suspicion of malpractice at the earliest possible stage. Concerns may be raised with the People Team or with the Managing Director.
Sonin will ensure that individuals are aware that proven cases of Bribery and Corruption may result in a disciplinary investigation, sanction and in some cases a Criminal prosecution of individuals and the company.
4 Summary
Please contact the People team for further advice on this policy or the Managing Director if you have any concerns regarding bribery and corruption involving any party in its business dealings with the Company.