BRIBERY AND CORRUPTION POLICY
Integrating Solutions Limited will not tolerate bribery or allow improper offers or payments to or from its employees or consultants placed by the company with clients, where these relate to the duties/ responsibilities associated with that placement.
The company will ensure that all employees are made aware of this policy by:
• Explaining this policy to all new employees as part of the company’s formal induction procedures and documenting this.
• Including reference to this policy in employment contracts for employees and contracts for services for all consultants.
• Displaying this policy in company offices and issuing a copy of this policy to all Managers.
• Any supplier or sub-contractor whose duties and responsibilities cover activities where this policy would be relevant shall be identified by the Directors and shall be issued with a copy of this policy and required to comply with it.
To support employees in their compliance with this policy, the company confirms the following:
• Employees should consult their line manager, if they consider that they have been offered a bribe or form of improper payment or they consider that they may have come across evidence of such practices. Any such incident should then be referred to the Directors who will ensure that it is investigated in an appropriate manner.
• Minor gifts, such as souvenirs or corporate gifts may be accepted where their estimated value is less than £75. Any gift potentially exceeding this or any money offered must be referred to the Directors who shall record the circumstances and decide on appropriate action.
• Hospitality offered shall be reviewed in advance by a Director and, if appropriate, approved by him in writing.
• Meetings with sales reps / Managers shall include a review of any instances of any of the above and the Directors shall ensure that any significant discussion and all agreed actions associated with these are recorded.
• The annual management review, held in accordance with the company’s will review any reported instances and confirm action taken, confirm the identified level of compliance with the policy and review the policy.