1. Policy Statement
Clearscan Environmental Ltd is committed to conducting business ethically and in compliance with all applicable anti-bribery and corruption laws, including the UK Bribery Act 2010. We have a zero-tolerance policy towards bribery and corruption in any form.
2. Scope
This policy applies to:
- All directors, officers, and employees
- Contractors, consultants, and agents acting on our behalf
- Suppliers and other third parties in our business relationships
3. What Is Bribery
Bribery is offering, promising, giving, accepting, or soliciting an advantage as an inducement for an action that is illegal, unethical, or a breach of trust. This includes:
- Cash payments or cash equivalents
- Excessive gifts, hospitality, or entertainment
- Political or charitable contributions made to gain improper advantage
- Facilitation payments
4. Prohibited Conduct
You must not:
- Offer, promise, or give a bribe to any person
- Request, agree to receive, or accept a bribe from any person
- Bribe a foreign public official to obtain or retain business
- Engage in any activity that might lead to a breach of this policy
5. Gifts and Hospitality
Modest gifts and hospitality may be acceptable when they are:
- Given or received in good faith
- Not intended to influence business decisions
- Reasonable and proportionate in value
- Properly recorded and transparent
Any gifts or hospitality above a nominal value must be approved in advance by management.
6. Record Keeping
We maintain accurate financial records and implement appropriate internal controls to evidence legitimate business transactions. All expenses must be documented with receipts and approvals.
7. Reporting Concerns
If you suspect or witness bribery or corruption, you must report it immediately to [email protected]. We protect whistleblowers who report concerns in good faith from any retaliation.
8. Consequences of Breach
Violation of this policy may result in disciplinary action, including dismissal, and may also lead to criminal prosecution. We will not hesitate to terminate relationships with third parties who breach this policy.
9. Training and Communication
All personnel are made aware of this policy and receive appropriate training. We regularly review and update our procedures to ensure continued effectiveness.
10. Review
This policy is reviewed annually by the Board of Directors to ensure it remains effective and reflects current legal requirements and best practices.
11. Contact
For any enquiries regarding this policy, please contact us at [email protected].