Bribery, Gifts & Entertainment Policy

Policy statement

It is emu24's policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, and to implement and enforce effective systems to counter bribery and corruption.

emu24 is required to uphold all laws relevant to countering bribery and corruption in all jurisdictions in which we operate. Primarily, emu24 remains bound by UK laws, including the Bribery Act 2010, and this applies to our conduct both in the UK and abroad.

Purpose

The purpose of this policy is to:

• Clarify what and how the Bribery Act 2010 relates to emu24
• Set out emu24's responsibilities, and the responsibilities of any person working for us, to observe and uphold our policy to prevent bribery and corruption
• Provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues

What are bribery and corruption?

Bribery

Bribery is where a person or organisation, directly or indirectly, offers, promises, gives, requests or accepts any financial or other advantage to induce another person or organisation to act improperly in the performance of their functions, or where receiving the advantage would cause the other person to act improperly.

It is a criminal offence to offer, promise, give, request or accept a bribe. As an individual, if found guilty, you could face up to ten years' imprisonment and/or a fine. As an employer, if emu24 fails to prevent bribery it can face an unlimited fine, exclusion from tendering for public contracts, and reputational damage.

Corruption

Corruption is the abuse of entrusted power or position for private gain.

Hospitality & entertainment

Hospitality or entertainment is only permitted where the purpose is to establish or maintain good business relationships, improve emu24's image, or market our services effectively.

• The event must be business-appropriate and proportionate to the relationship.
• An Authorisation Form must be completed and approved in advance by a Director for any hospitality valued at £100 or more per person.
• No hospitality should be offered to a Procurement Function member at any time.
• No hospitality should be offered or received within six months preceding a tender, contract renewal or contract amendment.

Gifts

Gifts of modest promotional value (e.g. emu24-branded stationery) may be provided without authorisation. Cash or cash equivalents must never be given or received. Any gift that cannot be returned to the sender should be donated to charity.

Facilitation payments

Facilitation payments and kickbacks are illegal. emu24 does not make facilitation payments of any kind, whether made directly or through agents or intermediaries. If you are asked to make a payment on behalf of emu24, always request a receipt and raise any concerns with a Director immediately.

Reporting concerns

emu24 operates a ‘speak up’ culture. If you suspect bribery or corruption, report it promptly to a Director or use the company's whistleblowing procedure. All reports will be investigated confidentially. No employee will be penalised for raising a concern in good faith.

Breaches of this policy

Any breach of this policy will be dealt with in accordance with the Company's Disciplinary Procedure and may constitute gross misconduct resulting in dismissal. Criminal conduct will be reported to the appropriate authorities.

Responsibilities

The Managing Director has overall responsibility for this policy. All employees and representatives are responsible for reading, understanding and complying with this policy and reporting any concerns without delay.