ANTI-BRIBERY & ANTI-CORRUPTION CODE OF CONDUCT
As an employee, contractor, consultant, temporary worker or anyone else operating on behalf Oakmont Consulting,we require you to abide by our Anti-Bribery & Anti-Corruption Policy at all times.This means that you are required to:
Familiarise yourself with the key elements of the Bribery Act 2010 and be familiar with your obligations under our Anti-Bribery & Anti-Corruption Policy.
Act honestly and with integrity in all your dealings.
Notify your line manager of any alleged or suspected instances of bribery, corruption or malpractice.
Specifically, this means that you must:
· Never offer, promise, solicit, demand, give or accept any form of bribe in return for business or commercial advantage; or any other type of favourable treatment (outside of the company’s commission or remuneration scheme).
· Not act improperly or offer / accept incentives, gifts or hospitality with the intention of persuading anyone to act improperly.
· Not make political contributions, donations or sponsorships and so avoid the perception that the intention is to gain an advantage as a direct result of the contribution, donation or sponsorship.
· Not engage a politician, former politician or candidate for political office as a consultant under any circumstances.
· Not attempt to influence or incentivise a current or former public official (i.e. an official who exercises a public function or acts on behalf of a public organisation; or anyone who holds a legislative, administrative or judicial position of any kind, whether appointed or elected) in the performance of their duties either in the UK or internationally.
· Not endeavour to speed up a routine administrative process either directly or indirectly via a facilitation or grease payment (however small) to a public official.Any request for such payments must also be refused and reported immediately to a Line Manager.
· Never accept or offer corporate hospitality or gifts which could be considered an incentive or enticement, particularly if they have the potential to place you under any obligation or if they have the potential to create any type of conflict of interest.This excludes promotion gifts without a significant value (e.g. stationery, chocolates or other gifts with a value of under £50 GBP).Any other gifts not falling into this category must be passed to the Line Manager who will return it to the donor and explain the company policy.
· Report any allegation or suspicion of bribery, corruption, facilitation payments or malpractice to your Line Manager.Any disclosure you make will be kept confidential during the investigation to the extent that it is practicable and appropriate.
You must also disclose any anticipated conflict of interest which may have the potential to interfere with your loyalty or objectivity while carrying out your job.This means you must disclose to your Line Manager any relationship with employees or representatives of any client, supplier, business associate or competitor which may influence or appear to influence your business judgement.Specifically, you must tell us if you:
Have a relative or close personal relationship with someone who is employed by a client, supplier, business associate or competitor
Have a significant interest in a company that we do business with;
Are required to supervise a family member or person with whom you have a close personal relationship.
Have a second job.
Have a family member who is a current or former Government or public official or a candidate for political office.
Have been charged with fraud, misrepresentation, bribery, corruption, tax evasion, terrorism or other related activities or have been charged with any criminal act.
Disciplinary action may be taken against any employee who acts in breach of this code of conduct or our Anti-Bribery & Anti-Corruption Policy and this may include summary dismissal.Consultants, contractors or temporary workers acting on behalf of the company who breach this code of conduct or Anti-Bribery & Anti-Corruption Policy may be subject to having their contract suspended pending investigation or terminated with immediate effect.
Breaches of the Bribery Act 2010 may also result in you being held personally liable, and if found guilty, subject to receiving a criminal record and up to 10 years’ imprisonment.
Declaration
I confirm that I understand the Code of Conduct detailed above and that I have disclosed any information of which the company should be made aware.I also understand that failing to disclose required information or giving any incorrect or misleading information could lead to my subsequent dismissal, or withdrawal / termination of assignment.
Name: Paul Stevens