ANTI-BRIBERY AND CORRUPTION POLICY

INTRODUCTION

1. Delivered Social Ltd conducts its business in a legal and ethical manner. Company employees and any other associated person acting on Delivered Social Ltd’s behalf are responsible for acting honestly and with integrity by ensuring that their activities, interests and behaviours do not conflict with these obligations, regardless of their seniority. These parties are referred to as ‘staff’ below.

2. This policy, based on the anti-bribery legislation (the Bribery Act 2010), requires that staff must not either directly or indirectly:

a) Offer, give, solicit or accept any bribe, either in cash or any other form of inducement, to or from any person or company, wherever they are located and whether they are a public official or body, or private person or company.
b) Gain or retain any commercial, contractual or regulatory advantage through unethical or illegal means when conducting business on behalf of the company.

3. Staff and associated persons must understand and strictly comply with the UK anti-bribery laws in all countries of the world.

DEFINITIONS

4. Bribery is the offer, promise, giving, demanding or accepting of an advantage as an inducement for an action which is illegal, unethical, a breach of trust or the improper performance of a contract. Inducement can take the form of gifts, hospitality, fees, rewards, jobs, internships, examination grades, favours or other advantages. It does not matter whether the bribe is given or received directly or through a third party or whether it is for the benefit of the recipient or some other person.

5. Corruption is the misuse of entrusted power for personal gain.

6. An associated person provides services to Delivered Social Ltd or acts on the company’s behalf and could be an employee of any type, consultants, agents and other forms of intermediaries and subsidiaries. Undergraduate and postgraduate students are not normally considered as associated persons unless they are themselves contracted by the University to provide a service. However, research students are likely to be considered as associated persons in respect of the conduct of their research and for activities such as fieldwork.

7. A foreign or government official could include a public official, whether foreign or domestic; a political candidate or party official; a representative of the government-owned or majority-controlled organisation; or an employee of a public international organisation.

8. Facilitation payments are unofficial financial payments or other advantages (either directly or indirectly) made to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has legal or other entitlement.

PRINCIPLES

9. This policy applies to all of Delivered Social Ltd’s activities and operations and to all of its dealings and negotiations with third parties in all countries in which its employees, agents, partners and associates operate. All employees and individuals working on behalf of, under contract from or in collaboration with any part of the company or with its employees are required to comply with this policy.

10. Delivered Social Ltd has a zero-tolerance approach to bribery and corruption and as such, all forms of bribery and corruption are prohibited. A bribe does not actually have to take place – just promising to give or agreeing to receive a bribe is prohibited.

11. Delivered Social Ltd will address the risks of bribery by ensuring adequate and proportionate measures are developed and implemented to mitigate them.

12. Arrangements with third parties will be subject to clear contractual terms, including specific provisions requiring them to comply with minimum standards and procedures relating to bribery and corruption. Delivered Social Ltd will not engage, or continue business with, any individual or third party who we know or reasonably suspect of engaging in bribery or corruption.

13. No staff member or associated person will suffer a penalty or other adverse consequences for refusing to pay bribes even if a refusal may result in loss of business or a delay in proceedings.

14. The prevention, detection and reporting of bribery are the responsibility of all staff. They should raise any concerns or allegations of bribery or corrupt activity with their line manager. Where staff feel they are not able to report in this way, they should report them through Delivered Social Ltd’s Whistleblowing Policy.

15. Delivered Social Ltd will ensure it takes appropriate action in response to any reported incidents of bribery or corruption. Failure to comply with this Policy will lead to disciplinary action and proven allegations will lead to disciplinary action resulting in summary dismissal. In relevant cases the police and the Serious Fraud Office (SFO) will be informed as certain offences carry criminal liability for individuals concerned and sanctions include significant fines and/or imprisonment.

PROPORTIONATE PROCEDURES

16. Delivered Social Ltd will ensure it has procedures in place to prevent bribery by staff and other persons associated with it, which are proportionate to the bribery risks it faces and to the nature, scale and complexity of Delivered Social Ltd’s activities.

RISK ASSESSMENT

17. Line managers or their nominee are responsible for ensuring risks are assessed and appropriate action taken to comply with this Policy, including reporting the identified risks and implementation of actions within their Business Plans.

DUE DILIGENCE

18. Delivered Social Ltd will apply due diligence procedures, taking a proportionate and risk-based approach, in respect of persons and organisations that perform or will perform services for or on behalf of the company in order to mitigate identified bribery risks.

19. Where appropriate, line managers or their nominee will complete sufficient due diligence when entering into arrangements with others to ensure they are not acting corruptly and to periodically monitor their performance to ensure ongoing compliance. They will take appropriate action in response to any information uncovered as a result of due diligence which gives rise to concern and reports any such actions.

COMMUNICATION

20. Delivered Social Ltd ensures that its bribery prevention and associated policies and procedures are embedded and understood throughout the organisation through internal and external communication.

21. Line managers or their nominee are responsible for ensuring the communication of Delivered Social’s Anti-Bribery and Corruption Policy and other relevant policies to associated person(s). Line managers will also monitor and review their procedures and action plans to ensure their suitability, adequacy and effectiveness in relation to this Policy and implement improvements as appropriate.

TOP LEVEL COMMITMENT

22. This Anti Bribery and Corruption Policy is reviewed annually to ensure fitness for purpose.