Website Anti-Bribery Policy

SLiK Media Ltd (the ‘Company’) is committed to conduct all aspects of its business in an honest and ethical manner at all times which means having effective systems in place to counter and discover bribery.

Under the UK Bribery Act 2010 then bribery and corruption undertaken by individuals is punishable by up to ten years imprisonment. Companies involved in corruption, or with inadequate systems in place to prevent it, could face an unlimited fine and will be excluded from tendering for Government contracts.

Policy

The Company has a zero-tolerance policy with regards to bribery and this document is intended to advise individuals on what that covers and how it is enforced.

This policy applies to all staff employed by the Company. This includes permanent and fixed-term staff employed by the Company, and any contractors, consultants or other persons acting under or on behalf of the Company.

The Company and its staff will not:

  • Make contributions of any kind (monetary or otherwise) with the purpose of gaining any advantage commercially.
  • Provide gifts or hospitality with the intention of persuading anyone to act improperly.
  • Make, or accept, gifts of any kind (monetary or otherwise) in return for providing any kind of commercial advantage.


Company Responsibility

The Company will:

  • Keep appropriate internal records detailing the business reason for any payments to a third party.
  • Provide a safe and encouraging environment where employees can freely raise concerns about any issue or suspicion of bribery.
  • Take concerns about bribery seriously and protect any employee who makes a report from any negative treatment for making a report, even if that report turns out to be incorrect.


Employee Responsibility:

Employees must not:

  • Accept, request or offer any type of incentive/gift (financial or otherwise) to any person or company in return for providing anything that could be construed as preferential treatment.


Non-Compliance

The enforcement of this policy is not just the role of management and the Directors, it is the responsibility of all staff to remain vigilant of breaches or suspected breaches and report them as soon as they are discovered. Should a staff member feel apprehensive about making a report then they should seek the support of their line manager.

Any member of staff refusing to observe the terms of this anti-bribery policy, or being found to have known about a breach yet not reported it, will be liable to disciplinary action in accordance with the Company’s Disciplinary Policy up to and including dismissal based on the severity of the issue.

Monitoring Policy

The application of, and adherence to this policy will be monitored on an on-going basis with amendments made as necessary to ensure it remains as effective as possible.

Reviewing Policy

This policy will be reviewed and, if necessary, revised when there are organisational changes, changes to the bribery laws, or as a result of monitoring.

Policy Amendments

Should any amendments, revisions, or updates be made to this policy it is the responsibility of the Company senior management to see that all relevant employees receive an updated copy via the HR system, written notice that there is an amended policy for them to review and reminders at the internal meetings to ensure everyone has reviewed the document.

Additional Information

If any member of staff requires additional information or clarification regarding this policy, or they disagree with any part of it, then please contact your line manager.

If anyone external to the company requires clarification then please contact your main point of contact for the company, or phone us on 01327 315168.


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