Anti Bribery Policy
1. Policy Overview
Causeway Technologies will conduct all of its business in an honest and ethical manner. The company takes a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all its business dealings and relationships whenever it operates.
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
Bribery and corruption are punishable for individuals by up to ten years imprisonment and if Causeway Technologies is found to have taken part in corruption, it could face an unlimited fine, be excluded from tendering for public contracts and face damage to its reputation. Causeway Technologies takes its legal responsibilities very seriously.
To ensure compliance with the Bribery Act 2010, the company has undertaken and documented a thorough risk assessment. This policy along with the company promoting a culture where bribery is not acceptable will ensure compliance with this act.
This policy applies to all individuals working at all levels and grades, including senior managers, officers, employees (permanent, fixed-term or temporary), consultants, contractors, trainees, seconded employees, homeworkers, casual workers, agency employees, volunteers, interns, agents, sponsors, or any other person associated with Causeway Technologies or any of our subsidiaries or their employees, wherever located.
This policy prohibits the offering, promising, making, giving, requesting agreeing to receive, accepting, receiving or facilitation of any inducement which results in personal gain or advantage to the recipient or any person or body associated with the recipient, and which is intended to influence the decision of the recipient.
2. Example of offering a bribe
You offer a potential client tickets to a major sporting event BUT ONLY if they agreed to do business with the company. It is acceptable to make this offer but not if you are making the offer to gain a commercial and contractual advantage.
3. Example of receiving a bribe
A supplier gives your nephew a job but makes it clear that in return they expect you to use your influence within the company to ensure that the company continues to do business with them.
4. Example of bribing a foreign official
You arrange for the company to pay an additional payment to a foreign official to speed up an administrative process.
5. Gifts and Hospitality
This policy does not prohibit normal and appropriate hospitality given or received to or from a third party. Third party means any individual or organisation that you come into contact with during the course of your employment with Causeway Technologies. This includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
The giving or receipt of gifts is not prohibited if it is not made with the intention of influencing a third party to obtain or retain business or a business advantage.
The gift or hospitality should be reasonable and justifiable and the intention behind the gift should always be considered.
6. Facilitation payments and Kickbacks
The Company will not accept facilitation payments or “kickbacks”.
Facilitation payments are small, unofficial payments made to secure or expedite a routine government action by a government official. They are not common in the UK but are common in other jurisdictions.
Kickbacks are payments made in return for a business favour or advantage.
7. Employee Responsibilities
Causeway Technologies’ policy is to operate within the country’s laws and regulations, and all employees are expected to co-operate in this by adhering to all laws, regulations, policies and procedures.
In the event that an employee has reason to believe or suspect that a conflict with this policy has occurred or may occur in the future, the employee must notify his or her manager.
Employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with the Company’s expenses policy.
A breach of this policy will be regarded by the Company as a disciplinary offence.
8. Communication
Causeway Technologies will communicate this Policy and its zero-tolerance approach to bribery and corruption across the organization and to sub-contractors and suppliers.
9. How to Raise a Concern
The employee is encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your own manager.
Concerns should be reported by following the procedure set out in the Company’s Whistleblowing policy.
Causeway Technologies aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy.
10. Monitoring and Review
The company will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness.
11. Potential risk scenarios: ‘Red Flags’
The following is a list of possible red flags that may arise and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
If the employee encounters any of these red flags while working for the Company, the employee must report them promptly to his or her manager.
- You become aware that a third party engages in, or has been accused of engaging in, improper business practices;
- You learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials;
- A third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
- A third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
- A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
- A third party requests an unexpected additional fee or commission to "facilitate" a service;
- A third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
- A third party requests that a payment is made to "overlook" potential legal violations;
- A third party requests that you provide employment or some other advantage to a friend or relative;
- You receive an invoice from a third party that appears to be non-standard or customised.