HML Anti-Bribery & Corruption Policy
HML recognises that bribery and corruption have an adverse effect on business and communities in which they operate in. Failure to identify and act upon bribery or corruption can break laws and basic human freedoms, distorting free trade and competition. Our definitions of bribery and corruption are below;
- Bribery - The act of taking or receiving something with the intention of influencing the recipient in some way favourable to the party providing the bribe.
- Corruption - Giving or obtaining advantage through means which are illegitimate, immoral, and/or inconsistent with one's duty or the rights of others.
Company Statement
HML will not tolerate any form of Bribery or Corruption and seeks to act with honesty and integrity in all of its business dealings. We will immediately and thoroughly investigate any allegation of bribery or corruption, and will take the strongest action. Breaches of this policy may be considered to be gross misconduct.
Laws and Regulations
HML is committed to applying high standards of honesty and integrity across our business. Our Bribery and Corruption Policy mirrors the statutory requirements applicable in the UK.
Policy and Practices
The HML Bribery and Corruption Policy applies to all employees, agency workers, consultants and contractors, irrespective of their level or functions they perform within the Company.
HML expects our business partners, suppliers and contractors to act with utmost integrity and without actions or thoughts involving bribery and/or corruption.
Responsibilities
All employees, consultants, contractors and agency workers; and any individual working directly for the business (including agents) are required and agree to operate within the following guidelines:
- To always act with honesty and integrity and support HML's policy relating to bribery and corruption.
- Not to offer or make any bribe, outlandish or unauthorised payment or incentive of any kind to anyone.
- Not to solicit business by offering any bribe, unorthodox or unofficial payment to customers or potential customers.
- Not to accept any kind of bribe, unorthodox or unusual payment or inducement that would not be authorised by HML in the ordinary course of business.
- To refuse any bribe or outlandish payment and to do so in a manner that is not open to misunderstanding or giving rise to false expectation; and to report any such offers.
- Not to make facilitation payments. These are payments used by businesses or individuals to secure or accelerate a service or product. The Company will not tolerate or overlook such payments being made.
- To report any breaches of the policy, if you suspect Bribery or Corruption is occurring or has occurred previously or if you are unclear on procedures or your responsibilities.
What to do if you become aware or suspect there is breach of the policy
If you become aware of Bribery or Corruption occurring you should report this to a member of staff without delay. If you know or suspect they will not be able to act on the information impartially you should contact the Managing Director.
The information will then be collated and assessed.
This policy should be read alongside our core values and your individual contract of employment.
Any breach of policy by any employee will be considered as grounds for disciplinary action, and may be considered to be gross misconduct. A breach by a contractor or consultant will be considered grounds to terminate any contract or agreement with that individual or Company.
Preventative Measures
As further preventative measures we have set out the following guidelines:
- Any expenditure by company to third parties in excess of £50.00 relating to gifts or entertainment must be authorised in advance by a Director.
- All gifts and gratuities (of any value) must be declared by employees and employees must not receive any gifts or gratuities at their home address.
- Gifts and gratuities include: physical gifts; entertainment; corporate hospitality; vouchers; free or discounted goods or services; free or discounted use of facilities, property or any other items from suppliers, clients or other third parties.
