Anti-Bribery Policy

General Statement of Policy

  1. du Boulay Projects Ltd (hereafter known as the company) is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every member of staff and individual acting on our behalf is responsible for conducting company business honestly and professionally.
  2. We consider that bribery and corruption have a detrimental impact on business by undermining good governance and distorting free markets. The company benefits from conducting business in a transparent and ethical way and by helping to ensure that there is honest, open, and fair competition in our sectors. Where there is a level playing field, we can lead the market through innovation and by delivering excellent services to our clients.
  3. We do not tolerate any form of bribery by, or of, our members of staff or any persons or companies acting for us or on our behalf. We are committed to implementing and enforcing effective systems to prevent, monitor and eliminate bribery, in accordance with the Bribery Act 2010.

PART 2 – Responsibilities

Under the Bribery Act (2010) this Anti-Bribery Policy applies to all members of staff of the company, and they are required to familiarise themselves and comply with the policy. A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

PART 3 – Method

3.1 INSTRUCTION

Members of staff and others acting for or on behalf of the company are strictly prohibited from making, soliciting, or receiving any bribes or unauthorised payments. As part of our anti-bribery measures, we are committed to engage only in transparent, proportionate, reasonable, and bona fide hospitality and expenditure.

3.2 DISCIPLINARY ACTION

A breach of the Anti-Bribery Policy by a member of staff will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal. Members of staff and other individuals acting for the company should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for the company.

We will not conduct business with service providers, suppliers or representatives that do not support our anti-bribery objectives.

3.3 MONITORING

The success of our anti-bribery measures depends on everyone playing their part in helping to detect and eradicate bribery. Therefore, all staff members and others acting for, or on behalf of the company are encouraged to report any suspicious activity to the Managing Director. The company will support any individuals who make such a report in good faith.

3.4 PUBLICATION OF THIS POLICY

This policy is available to company Members of Staff in IT system.

This policy is available to Suppliers on the Company’s website.

PART 4 – Review

Following a formal investigation under this policy, the manager and investigator involved should consider whether this policy has been effective in addressing the issues and report any problems or suggestions for improvement to the Managing Director.

Staff are invited to comment on this policy and suggest ways in which it might be improved by contacting the HR Manager.