Fair dealing, against corruption

If you would like this Policy in another format (for example: audio, large print) please contact us by sending an email to dc@seeio.co.uk or by calling us on 0203 855 5776. If you have any questions about the Site or this Policy, please contact us.

Culture

It is our policy to conduct all our business honestly and ethically. We do not condone or tolerate bribery and corruption.  We are committed to acting professionally, fairly and with integrity in our relationships wherever we operate in the world, implementing and enforcing effective systems to counter bribery and corruption.

We are bound by UK laws, including the Bribery Act 2010, in our conduct at home and abroad. We will uphold all laws relevant to countering bribery and corruption in all jurisdictions in which we operate.

We may amend this policy at any time. It exists on our website for convenient access.

Purpose

The purpose of this policy is to set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on bribery and corruption; and provide guidance to those working for and on our behalf on how to recognise and deal with bribery and corruption issues.

You are invited to comment on this policy and suggest ways in which it might be improved.

Who must comply

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.

“Third party” means any individual or organisation you come into contact with during the course of your work for us, and 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.

Definitions

“Bribery” is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.

An “advantage” includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.

A person acts “improperly” where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.

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

Anti-bribery and Anti-corruption obligations

It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years’ imprisonment and/or a fine.

Employers who do not prevent bribery face fines, exclusion from tendering for public contracts, and damage to reputation. We take our legal responsibilities seriously.

Our no-tolerance approach to bribery and corruption must be a consistent line taken by everyone in our Company with all of our suppliers, contractors and business partners at the outset of and during our business relationship with them.

We do not make, and will not accept, facilitation payments or ‘kickbacks’ of any kind.

Facilitation payments, also known as ‘back-handers’ are small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official).  Kickbacks are typically payments made in return for a business favour or advantage. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the CEO of our company.

We do not make contributions to political parties. We do not make charitable donations.

Reasonable and appropriate hospitality or entertainment to / from third parties is allowed for the purposes of:

Reimbursing a third party’s expenses or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery, if a genuine and reasonable business expenses. The intention behind third party reimbursing should always be considered.

Reimbursing a third party’s expenses or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery, if a genuine and reasonable business expenses. The intention behind third party reimbursing should always be considered.

It is not acceptable for any of us to:

The following may arise in any working relationship and should cause you to stop and report your concerns to the CEO of this company. The list is not intended to be exhaustive and is for illustrative purposes only:

a third party engages in or accused of engaging in improper business practices;

a third party with a reputation for paying bribes;

a third party insisting a commission or fee before signing a contract with us or carrying out a government function or process for us;

a third party seeking payment in cash and/or refusing to sign a formal commission or fee agreement, or to provide an invoice or receipt;

a third party requesting that payment is made to a country or location different from where the third party resides or conducts business;

a third party requesting an unexpected additional fee or commission to “facilitate” a service;

a third party demanding lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;

a third party requests paying money to overlook potential violations;

a third party requests employment or other advantage to a friend or relative;

invoice from third party that seems non-standard or customised;

a third party refuses to put terms agreed in writing;

invoiced for a commission or fee payment that appears large given the service provided;

a third party requests use of an agent, intermediary, consultant, distributor or supplier not typically used by or known to us;

you are offered an unusually generous gift or lavish hospitality by a third party.

Record-keeping

We keep financial records and have appropriate internal controls in place to evidence the business reason for making payments to third parties.

Our staff must declare and keep a written record of all hospitality or gifts given or received, which will be subject to managerial review.

You must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

How to raise a concern

Our staff must read, understand and comply with this policy, and are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage, by notifying must their manager or CEO as soon as possible, including if unsure about whether or not breach has taken place.

Individuals are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises concerns in good faith, even if mistaken.  We are committed to ensuring no-one suffers detrimental treatment as a result of refusing to take part in bribery or corruption or because of reporting in good faith.   

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, and likely dismissal for misconduct or gross misconduct. We will always consider terminating our relationship with organisations or people working on our behalf if they breach this policy.

Training and communication

Training on this policy forms part of the induction process for all individuals who work for us, and extra training will be provided as necessary.

Last updated:

19 Sep 2023

01 May 2022

18 December 2021

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