Anti-Bribery Policy
1. INTRODUCTION
Evelors Limited (hereinafter Evelors) is committed to conducting its business with the highest ethical standards and in compliance with all applicable anti-bribery and anti-corruption laws. This policy outlines our approach to preventing and prohibiting bribery and corruption in all aspects of our business operations.
2. DEFINITION
Bribery within Evelors is defined as the offering or accepting of gifts, loans, payments, rewards, or advantages for personal gain, with the intent to encourage dishonest, illegal, or trust-breaching actions in the course of business.
Corruption, characterised by the misuse of office or power for private gain, encompasses bribery, involving the exchange of money, gifts, meals, entertainment, or other valuable items to induce dishonest or illegal conduct.
Recognising bribery as a criminal offence, Evelors strictly prohibits any form of bribery. We mandate compliance with the highest ethical standards and applicable anti-bribery laws from all individuals associated with our business.
Upholding integrity and transparency, we maintain a zero-tolerance stance towards corrupt activities, whether initiated by Evelors employees or third parties acting on our behalf.
3. PURPOSE
The purpose of this policy is to convey to all employees and interested parties of Evelors the rules of the company in relation to our unequivocal stance towards the eradication of bribery and corruption and our commitment to ensuring that Evelors conducts its business in a fair, professional and legal manner.
4. ZERO TOLERANCE FOR BRIBERY
Evelors has a zero-tolerance policy for any form of bribery or corruption. All employees, contractors, consultants, and third parties acting on behalf of the company are strictly prohibited from engaging in bribery or corrupt activities.
5. OFFENCE
Engaging in certain actions constitutes a criminal offence under the law, including:
– Offering a bribe;
– Accepting a bribe;
– Bribing a foreign official;
– Failing, as a commercial organisation, to prevent a bribe.
It is important to note that being found guilty of bribery in court may result in severe consequences, including up to 10 years of imprisonment and/or an unlimited fine for individuals. Additionally, the company itself could face prosecution and be subject to financial penalties. Stay informed and compliant to avoid legal repercussions.
6. APPLICABILITY
This policy applies to all individuals working for Evelors Limited, including employees at all levels, directors, officers, contractors, consultants, and any other parties acting on behalf of the company. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement.
We will encourage the application of this policy where our business involves the use of third parties e.g. suppliers, contractors.
7. PREVENTION OF CORRUPTION
All employees, regardless of their position, are responsible for preventing corruption. This includes:
a) Distinguishing between gifts and bribes:
Employees should understand the difference between acceptable business gifts and entertainment and improper bribes. See the attached guidelines for examples.
b) Recognising types of corruption:
Familiarise yourself with various forms of corruption that may occur in the business context, including bribery, extortion, embezzlement, and money laundering.
c) Avoiding conflicts of interest:
Understand and adhere to the rules regarding conflicts of interest, and take appropriate steps to avoid or address potential conflicts.
8. POLICY
It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for the Evelors, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.
It is also prohibited to act in the above manner in order to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.
If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact a direct superior so that action can be taken if considered necessary. You may be asked to give a written account of events.
If you, as an employee or person working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this to the direct superior. You may be asked to give a written account of events.
Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.
The Company will ensure that all its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.
Evelors take any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.
We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self- employed, an agency worker, contractor etc.
9. RISKS AND CONSEQUENCES
Failing to prevent corruption poses serious risks to our business and reputation. Violations of this policy may result in disciplinary action, including termination of employment, legal action, and potential damage to the company’s reputation.
10. MONITORING AND REVIEW
Evelors is committed to regularly monitoring and reviewing this policy to ensure its effectiveness. We encourage employees to report any concerns or potential violations through our confidential reporting mechanism.
11. REDUCING AND CONTROLLING RISKS
The company will continually assess and implement measures to reduce and control the risks of bribery and corruption. This includes periodic risk assessments, training programs, and the implementation of internal controls.
12. GIFTS, HOSPITALITY, AND DONATIONS
Employees should not solicit or accept gifts, hospitality, or donations that could compromise their integrity or create a perception of impropriety. Any offers of such items must be reported to appropriate contact.
We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.
Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans given or received as a mark of friendship or appreciation.
Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present.
No gift should be given, nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from direct superior. Similarly, no gift nor offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from direct superior.
A record will be made of every instance in which gifts or hospitality are given or received.
As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.
13. BUSINESS CONDUCT GUIDELINES
All employees are expected to conduct business in a manner that upholds the highest ethical standards. This includes proper handling of contracts, accurate reporting, and interpretation of offered hospitality. See the attached guidelines for further details.
Evelors is steadfast in maintaining the highest standards of integrity and ethical conduct. This policy serves as a guide for employees to align their conduct with our commitment to preventing bribery and corruption.