Anti Bribery and Corruption Policy

Mission

This document provides information on our approach to dealing with bribery and corruption to ensure that the people acting on our behalf comply with effective anti-bribery and corruption policies and legislation.

 Purpose 

This policy is designed to help you to identify when something is prohibited so that bribery and corruption is avoided and provide you with help and guidance if you are unsure about whether there is a problem and who to contact if you need further advice.

Scope 

This policy applies to all Kerv employees and contractors and all geographical locations. This policy sets out a single standard that all Kerv employees must comply with, regardless of whether local law or practices might permit something to the contrary.

Policy

Whoever we may deal with, and wherever we may operate, we are committed to doing so lawfully, ethically and with integrity.  As part of this commitment, all forms of bribery and corruption are unacceptable and will not be tolerated. 

Bribery involves a financial advantage or leverage given or promised with the intention to encourage or reward a person to perform their responsibilities or duties improperly (it does not have to be the person to whom the bribe is offered that acts improperly) or when a financial or other advantage is requested, agreed to be received or accepted by another person with the intention of causing or rewarding them to perform their responsibilities or duties inappropriately.

Bribes can take many forms, for example, unreasonable gifts, entertainment or hospitality, kickbacks, political/charitable contributions, uncompensated use of company services or facilities; facilitation payments/payments or anything else of value made to a person to encourage them to perform their normal job more quickly and/or prioritise or favour a customer or supplier.

You must contact the Compliance Officer in the first instance to report or ask for advice if you feel concerned or are unsure if there is a problem. The Compliance Officer will investigate this as priority and escalate it to the Senior Management where necessary.

As general guidance:

• The giving or receiving gifts or hospitality is often an important part of maintaining and developing business relationships. All gifts and hospitality, however, should be for a genuine purpose, reasonable, and given in the ordinary course of business.
• approval will be required by an Executive Board member if a gift worth more than 50 pounds is given or offered.
• a bribe does not actually have to take place – just promising to give a bribe or agreeing to receive one is prohibited.
• it does not matter whether the bribe is given or received directly or through a third party for the benefit of the recipient or some other person.
• a breach of bribery laws can result in fines for both the company and the individual involved and, in some jurisdictions, could also result in imprisonment.
• you must not engage with any third party who you know or reasonably suspect of engaging in bribery.
• bribery is prohibited when dealing with any person whether they are in the public or private sector and the provisions of this policy are of general application.
• appropriate due diligence should be undertaken before any third parties are engaged. The appropriate level of due diligence will vary depending on the circumstances and you should use your judgement on a case-by-case basis. Kerv’s policies on supplier onboarding must be complied with.
• dealing with public officials poses a particular high risk in relation to bribery and corruption. Research when dealing with public officials as they have their own rules regarding the acceptance of gifts and hospitality, etc, and we must respect these rules where applicable.

If you suspect or observe anything that you think might be in contravention of this policy, you have an obligation to report it. You should raise your concerns with a member of the Governance Team and where necessary with a member of the Executive Board. Alternatively, you can report your concerns under the Whistleblowing Policy. All reports will be treated confidentially.

Any breach of this policy whether it is international or otherwise may lead to disciplinary action up to and including dismissal.

Responsibility

Kerv’s Senior Management Team, supported by the Governance Team, are responsible for this policy and its implementation. We commit to providing the relevant resource and to reviewing this policy annually and communicating it within the organisation and to external interested parties.

Legal Responsibilities

This policy actively complies and supports the UK’s Bribery Act 2010.

External Assurance

We appoint independent external auditors to assess and confirm our compliance with relevant standards that include ISO 27001, 27701 and 9001.  Reviews should occur on an annual basis.