Anti – Bribery Policy

BRIBERY

A bribe is an advantage used with the intention of inducing or rewarding improper performance of a function or activity. A bribe is requested with knowledge that this would also constitute the improper performance of a function or activity. Under this are two other types of briberies: Active and Passive briberies. Active bribery is when the internal action has been taken to encourage, imply, bestow, or promise an unfair, unlawful, improper or unethical advantage towards an individual, group, or organization, regardless if there is financial incentive or not.

Passive bribery is the acceptance of a bribe to induce a favourable investment or regulation, property transaction, or business income. Both Passive and Active briberies are considered by the government to be unlawful.

This policy consists of basic rules that all employees must strictly adhere to:

  • Do not offer, promise or pay bribes
  • Do not request, agree, accept or have any involvement in bribery

This policy does not prohibit all giving and receiving, or reasonable and proportionate offers to the recipient, provided that it is not used to influence them improperly. In terms of gifts, these should never be cash and must be modest at all times simply portraying a token of appreciation. Any REDS10(UK)Ltd representative proved to be performing such acts will be disciplined accordingly.

CORRUPTION

Corruption is dishonest or fraudulent conduct by those in power, running concurrently with behaviours similar to bribery. Imperceptible risks of corruption can make a company vulnerable; to refrain from being caught up in these employees must follow these principles:

  • Do not take advantage of your position within the company in regards to payments to ones- self or to others.
  • Do not use advantages to influence foreign officials for business without first discussing with a company solicitor.
  • Do not make payments to an individual which may put them in jeopardy of misusing their position or which includes both parties performing functions improperly.

Fraud is a wrongful or criminal deception intended to result in financial or personal gain. REDS10(UK)Ltd commits to building an anti-fraud culture and maintain high ethical standards amongst all employees and representatives. If the necessity should arise a full investigation will be carried out to abolish any suspicions, and guilty parties will be disciplined severely for committing such a crime.

MALPRACTICE

Malpractice is improper, illegal, or negligent professional behaviour. REDS10(UK)Ltd discourages these activities and urges employees to steer away from situations where
they could be involved or victimised by malpractice. The Directors of REDS10(UK)Ltd fully recognise and accept their responsibilities under the Bribery Act 2010. The Company does not tolerate any form of bribery by or of its employees, consultants, public officials, or any persons acting on behalf of the Company.

The Directors of the Company are also committed to preventing corruption, fraud and malpractice within the workplace. Through this policy we have implemented effective measures to prevent, monitor and eliminate these acts. This policy should be read in conjunction with Company Policies and Staff Handbook.

CONFLICTS OF INTEREST

A conflict of interest is to have a connection with a third party that is (or appears to be) against the Home and Communities Agency’s (HCA) best interests or having an unfair advantage against third-parties. In the event of a conflict of interest, it is required to report and disclose the behaviour and manage the conflicts accordingly.

This policy applies to all employees, temporary workers, consultants, contractors or agents, subsidiaries and associated companies acting on the behalf of the Company.