Countering Bribery and Corruption
Although this is not a new problem, bribery and corruption has been given increasing high visibility recently. The Bribery Act 2010 has reinforced the need for UK companies to conduct their businesses ethically and with integrity and transparency.
St. Modwen's policies and procedures in this regard exist to protect the Company, its employees, customers, agents and advisers from allegations of bribery and corruption and their business, legal and regulatory consequences that can result.
These are only effective when you understand why they are in place, work within them and take personal responsibility for the outcomes. Therefore you are urged to read them thoroughly and understand what you need to do. If you have any questions, then please raise them initially with your line manager or refer them to the Company Secretary.
Anti-Bribery and Corruption Policy
St. Modwen Properties PLC (the 'Company') expects its employees and all persons who act on its behalf to demonstrate honesty, integrity and fairness in all aspects of their business dealings and exercise appropriate standards of professionalism and ethical conduct in all of their dealings with the Company and our stakeholders. We also expect that our stakeholders will adopt these same standards in working with the Company.
The Company will therefore not tolerate any acts of bribery, or corruption in any form and has a 'zero tolerance' approach to any of these activities. In line with the requirements of the Bribery Act 2010, the Company, our employees or persons acting on our behalf will never seek, accept, offer a bribe, gift, or other improper payment as a reward for improper performance of a relevant function or activity, or participate in any kind of corrupt activity, either directly or through any third party.
Bribery is offering, promising, giving, accepting or soliciting of a financial or other advantage as an inducement to conduct that is illegal, unethical, a breach of trust or position, or which gives an improper business advantage. Inducements can take the form of cash, gifts, hospitality, loans, fees, rewards, services or donations. Whether they are provided to or received from public officials or private individuals, bribes are against the law and against our policy.
Corruption involves any of these activities: bribery, extortion, fraud, deception, collusion, cartels, abuse of power, embezzlement and money laundering.
We will always:
We will never:
Raising a concern
Remember, the longer we wait to resolve a concern, the worse it may become.
If you are in doubt about what to do or whether to speak up, it may help to ask yourself some simple questions:
Failing any of the above 'tests' indicates that you need to talk with someone about the concern you have. If you have any doubts about the proper course of action, always seek advice.
The procedure for raising a concern is set out in the whistleblowing policy.
Gifts and Hospitality
We make sure gifts or hospitality at work are reasonable, and we never offer or accept them if it may improperly influence a business decision or impair independence or judgement.
Gifts and hospitality: Invitations to social functions, sporting events, meals and entertainment, gifts of low value, small or customary tokens of appreciation… To foster goodwill or enhance business relationships, employees may occasionally receive or offer any of these things in connection with our business.
Any gifts or hospitality we receive or give in connection with our business should always be customary and reasonable in terms of value and frequency. Use your judgement and good sense. In principle, there is nothing wrong with genuine relationship-building gifts or hospitality.
But ask yourself, "Is this excessive? Is it a gift – or a bribe? Is it hospitality – or persuasion?" If you are struggling to justify it to yourself, it is probably not right.
In any case, you should obtain your line manager's written approval before offering or accepting any gifts or hospitality, as just the appearance of impropriety can be damaging. Form to either offer or receive gifts and / or hospitality must be completed and signed off by your line manager before offering or receiving to and from the third party.