Accepting Gifts & Benefits

The Bribery Act is now in force making it easier for the Serious Fraud Office to prosecute bribery and corruption offences which may result in an unlimited fine or up to 10 years in prison.  Whilst this legislation has been passed with the activities of very big businesses in mind, all businesses are open to allegations of bribery and fraud and the law covers everyone.

The Act brings in strict legislation regarding the inducement of bribes, therefore, we take the acceptance of gifts or benefits very seriously – these may be perceived as bribery.

Except as set out below, you are not permitted on a personal basis to make use of any services or be supplied with goods by any actual or prospective customers, contractors, or suppliers of the Company or related individuals or organisations.

If you wish to do this, you must inform the director(s) who has the authority to approve individual exceptions to this rule.  All exceptions must be recorded in writing. The taking of bribes is expressly forbidden, so you should be extremely careful when accepting gifts from customers.

You must not solicit and, except as set out below, you must not accept any gifts or benefits, whether financial, or in kind, from any actual or prospective customers, contractors, or suppliers of the Company or any other person or business with whom you are involved in relation to the Company’s business.

If you are offered any gift or benefit, whatever its nature or value you must always clear the position of the director(s) before accepting it.

If you are offered a gift or benefit as an inducement for preferential treatment, it must be refused or returned as appropriate and the most appropriate Director made aware. However, provided that there is no reasonable possibility of improper influence to the performance of your duties, and that your acceptance of the gift or benefit cannot be seen as a bribe (however unfounded), you will generally be permitted to accept small gifts from customers as per the rules below:

• Any normal business entertainment (for example, a meal or special event) to the value of £100.00 or
• Any gift or benefit under the value of £20.00 offered by a person or business as part of their normal marketing activities.

If you do accept a gift from a client or customer, you must inform the director(s). Any breach of these terms of your employment is likely to result in disciplinary action and may potentially constitute gross misconduct.