Anti-Corruption & Bribery Policy.
Policy statement (the “Statement”).
It is the policy of KSA Group Ltd (the “Company”) to conduct business in an honest & ethical manner. The Company takes a zero-tolerance approach to bribery & corruption. The Company is committed to acting professionally, fairly & with integrity in all its business dealings & relationships, wherever it operates, & in implementing or enforcing effective systems to counter bribery. The Company will uphold all laws relevant in countering bribery & corruption in all the jurisdictions, in which it conducts business. The Bribery Act 2010 (the “Act”) applies to conduct both in the UK & abroad.
Scope & applicability.
This Statement applies to all individuals & entities working for, or on behalf of the Company: at all levels & grades, whether permanent, fixed-term or temporary, & wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors & any other person who performs services for or on behalf of the Company (the “Workers”).
This Statement also binds any individual or organisation that Workers come into contact with during the course of their work & the running of the Company’s business: & includes actual & potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government & public bodies (including their advisers, representatives & officials), politicians & political parties (“Third Parties”).
What is bribery?
A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely:
The Company may also be liable under the Act, if it fails to prevent bribery by an associated person (including, but not limited to Workers & Third Parties) for the Company’s benefit.
Gifts & hospitality.
This Statement does not prohibit normal & appropriate gifts & hospitality (given & received) to, or from Third Parties, unless otherwise specifically stated. The Company provides guidance to Workers as to what is to be regarded as normal & appropriate gifts, & hospitality in terms of financial limits, subject to the principles set out below (the “Overriding Principles”), namely that any gift or hospitality:
The Company appreciates that the practice of giving business gifts varies between countries & regions, & what may be normal & acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable & justifiable both in the UK, & any other relevant country. The intention behind the gift should always be considered.
What is not acceptable?
It is not acceptable for any Worker (or someone on their behalf) to:
Facilitation payments & ‘kickbacks’.
The Company does not make & will not accept, facilitation payments or ‘kickbacks’ of any kind: such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.
Charitable Donations & sponsorship.
The Company only makes charitable donations & provides sponsorship that is legal & ethical under local laws & practices, & which are in accordance with the Company’s policies & procedures.
The Company keeps appropriate financial records & has appropriate internal controls in place which evidence the business reason for gifts, hospitality & payments made & received.