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.


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.


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.

Who must comply

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.

“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.


“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

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

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.

  1. establishing/maintaining good business relationships,
  2. improving image or reputation of the business brand,
  3. effectively marketing and presenting the product.

It is not acceptable for any of us to:

  1. where it will provide a business advantage for them or anyone else in return; where it would be unduly lavish or extravagant in the circumstances,
  2. accept gifts from political or government officials.

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.   

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.

Last updated:

19 Sep 2023

01 May 2022

18 December 2021

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