Anti-Bribery Policy

TGMS Ltd Anti-Bribery Policy

30 October 2012

  1. Introduction

1.1          TGMS Ltd (the Company) is committed to implementing and enforcing effective systems to counter bribery. Therefore, it is TGMS Ltd’s policy to conduct all aspects of its business in an honest and ethical manner at all times.

1.2          This policy applies to all individuals working for TGMS Ltd, including anyone providing services to TGMS Ltd such as consultants, or contractors/sub-contractors.

  1. Policy Aim

2.1          The aim of this policy is to help TGMS Ltd act in accordance with the Bribery Act 2010, maintain the highest possible standards of business practice, and advise individuals of TGMS Ltd’s ‘zero-tolerance’ to bribery.

  1. The Law

3.1          Under UK law (UK Bribery Act 2010), bribery and corruption is punishable for individuals by up to ten years imprisonment. If TGMS Ltd is found to have taken part in corruption or lacks adequate procedures to prevent Bribery, it could face an unlimited fine and be excluded from tendering for Government contracts.

  1. Policy Statement

4.1          This policy applies to all permanent and fixed-term staff employed by TGMS Ltd, and any contractors/sub-contractors, consultants or other persons acting under or on behalf of TGMS Ltd.

4.2          The Company will not:

  • Make or receive contributions of any kind with the purpose of gaining any commercial advantage.
  • Provide or receive gifts or hospitality with the intention of persuading anyone to act improperly, or to influence a public official in the performance of their duties.
  • Make, or accept, “Facilitation Payments” (kickbacks) of any kind.

4.3          The Company will:

  • Keep appropriate internal records that will evidence the business reason for making any payments to third parties.
  • Encourage employees to raise concerns about any issue or suspicion of malpractice at the earliest possible stage.
  • See that anyone raising a concern about bribery will not suffer any detriment as a result, even if they turn out to be mistaken.
  1. Employee Responsibility

5.1          Employees must not:

  • Accept any financial or other reward from any person in return for providing some favour.
  • Request a financial or other reward from any person in return for providing some favour.
  • Offer any financial or other reward from any person in return for providing some favour.
  • Make unofficial payments to officials in order to obtain any permission, permit or stamp; particularly in connection with international import/export or international permits.
  • Appoint any third party, contractor or supplier to act on behalf of TGMS Ltd who you know or have good reason to believe have engaged in any corrupt or unlawful conduct including any offences under the Bribery Act 2010.
  • Appoint or contract any third party for the purposes of being a ‘fixer’ to open doors to make connections for TGMS Ltd overseas.
  1. Gifts and Hospitality

6.1          This policy does not prohibit giving and receiving promotional gifts of low value, or normal and appropriate hospitality.

6.2          Receiving Business gifts:

  • Receiving promotional gifts of low value is normal and appropriate, however, gifts with a value exceeding £25.00 may not be accepted without approval from the Board of Directors. Any gift offered and then refused because of its value, must be reported to TGMS Ltd Anti-Bribery Officer and recorded.

6.3          Offering Business gifts:

  • Business gifts are primarily aimed at thanking customers and suppliers for their custom and loyalty, only authorised gifts may be given.

6.4          Receiving Hospitality:

The acceptance of corporate hospitality must be transparent; all invitations must be reported to the Board before an employee accepts any invitation. The following areas are exempt while attending conferences or seminars, sponsored by third parties.

  • business and travel expenses incurred
  • normal business lunches and meals

To ensure openness and transparency, all hospitality and entertainment must be recorded in the Hospitality and Entertainment Register located in X:\Live\TGMS Ltd\Anti Bribery Policy.

6.5          Offering gifts and hospitality:

  • Company hospitality is primarily aimed at thanking customers and suppliers for their custom and loyalty. All hospitality events must have approval from the Board of Directors.

6.6          Donations to organisations:

  • TGMS Ltd does not make contributions or donations to political organisations or independent candidates nor does it incur any political expenditure.
  • TGMS Ltd respects the right of individual employees to make personal contributions, provided they are not made in any way to obtain advantage in a business transaction.
  • No donations should be made to charities, political parties or other organisations without approval from the Board of Directors.
  1. Non Compliance

7.1          Staff

Failing to observe TGMS Ltd Anti-Bribery Policy may lead to disciplinary action in accordance with the TGMS Ltd’s Employee Handbook.

7.2          Associated Persons

In the event of a breach of the policy by other organisations, or individuals, TGMS Ltd will take appropriate action.

  1. Monitoring Policy

8.1          The policy will be monitored on an on-going basis to ensure that it addresses issues effectively.

8.2          The following will be monitored:

  • That all individuals working for TGMS Ltd are advised of the policy.
  • Assessment of any reported incident or related occurrence.

8.3          Monitoring of the policy is essential to assess how effective TGMS Ltd has been to, establish control of its obligations.

  1. Definitions

Bribe is a financial or other advantage offered or given to anyone to persuade them to or reward them for, performing their duties improperly, or, with the intention of influencing them in the performance of their duties.

Hospitality is the practice of being hospitable. This includes the reception and entertainment of guests / visitors.

Facilitation Payments are typically small payments made in return for a business favour or advantage.

  1. Reviewing Policy

10.1       This policy will be reviewed and, if necessary, revised in the light of legislative or organisational changes. Improvements will be made by learning from experience and the use of an established annual review.

  1. Policy Amendments

11.1       Should any amendments, revisions, or updates be made to this policy it is the responsibility of TGMS Ltd Board of Directors to see that all relevant employees receive notice. Written notice and/or training should be considered.

  1. Policy Implementation Notice

This is the policy statement of TGMS Ltd

The overall and final responsibility for this policy is that of the Board of Directors.

Iain James 30 October 2012