Anti-Bribery & Corruption Policy

Policy Statement

It is Sedgewall Policy to maintain the highest standard of ethics in its business dealings with clients or potential clients, its suppliers, its staff or any other interested party. Sedgewall is committed to conducting itself fairly, honestly, and lawfully in any of its business dealings. Sedgewall has a zero tolerance approach to bribery and corruption.

Sedgewall is bound by the laws of the UK, including the Bribery Act 2010 which governs our conduct in any dealings that we have in connection with the above parties.

Scope of policy

At Sedgewall, we believe in running and developing our business in a sustainable manner, for the benefit of all stakeholders. Those stakeholders will be; our owners, our clients, our staff, our suppliers, and the communities in which we operate.

We believe we have a responsibility to adhere to the highest standards of behaviour and care. This Policy therefore sets out the universal standards of individual and collective behaviour that we seek to apply to all our activities.

The general principles that underpin this policy align with our company values; we are Committed, Expert, Passionate, Responsible and Supportive. Therefore, we will:-

  • Treat our staff fairly and with respect for their dignity,
  • Implement policies and procedures to prevent slavery and human trafficking in all parts of our business, and within our supply chain,
  • Deal with clients with integrity, offering good value, high quality products and service with prompt redress if something goes wrong,
  • Embrace the aspirations of our clients,
  • Conduct our relationships with suppliers with honesty, fairness and mutual trust,
  • Comply fully with our legal obligations,
  • Monitor our ethical performance.

This policy aims to outline howwe do our business. We recognise that it would be impossible to produce a comprehensive set of rules that cover every situation that our staff might encounter in the course of their work. Instead, this policy seeks to provide a framework within which we expect our staff to operate, and some guidelines as to what may or may not be acceptable. Where a particular activity is clearly at odds with our ethics as an organisation and is deemed to be unacceptable in any circumstances, this is made clear in our policy. As a general rule, we expect people to make sensible and informed judgements about whether a particular activity, approach or way of working is ethical and likely to be acceptable, and to seek guidance from others within the company as required where they are unsure. This policy should be read in conjunction with the company’s specific policy on:-

  • Health, Safety and welfare,
  • The Environment.
  • Modern Slavery,
  • Equal Opportunities.

Bribery & Corruption

The Bribery Act 2010 (the ‘Act’) was enacted on 8thApril 2010 and its main provisions commenced in July 2011. Under the act, the main offences are bribing another person, being bribed, bribing a foreign official and a corporate offence of failing to prevent bribery.

As a result of this Act, certain actions abroad, which were acceptable business practise, will now constitute an offence in the UK if the person performing them abroad has a close connection to the UK, or if the related body is incorporated in the UK, or carries out part of its business in the UK.

Further, these offences will be judged according to an “expectation test”, which is what would a reasonable person in the UK expect in relation to the performance of the activity concerned (that is, not what behaviour is common in the place where the activity has taken place).

Anti-bribery and anti-corruption laws apply to all of Sedgewalls employees and any bribery or corruption is always contrary to Sedgewalls own standards of business conduct. Sedgewall employees must not under any circumstances make, or accept, any offers of bribery (this is widely defined and includes offers of services, money, gifts or entertainment). If any staff member is in any doubt regarding this, the staff member should speak to the General Manager. Any actual or suspected bribery must be reported to the GM.

Any employee suspected to have breached Sedgewall policy will be subject to a disciplinary investigation, which may lead to dismissal from their employment.

Any report by an employee of actual or suspected bribery will be treated in confidence and (provided that any such report is made in good faith in support of Sedgewalls commitment to zero tolerance to bribery and corruption) the employee protected from any reprisals in connection with their report.

Anti-Collusion

Sedgewall will not collude with others (including contractors, suppliers or service providers) in the pricing or submission of tenders or services, nor will Sedgewall enter into any agreement with any other person or body that they shall refrain from participating in any competitive tender, submission or pre-qualification process.

Gifts & Entertainment

The exchange of gifts and entertainment can build goodwill in business relationships, but can also create improper influence or the appearance of improper influence. Sedgewall can provide guidance for staff, in order to help them determine whether gifts may be accepted.

Supervision of others

Those who supervise others have additional responsibilities for maintaining compliance with this policy. They must:-

  • Lead by example, promoting compliance and ethics in all of their behaviours,
  • Make sure that those who report to them understand the requirements of this policy and have the resources to meet them,
  • Monitor compliance and ethics of subordinate staff , taking any appropriate action to address any shortcomings,
  • Use reasonable care to monitor the behaviour or third parties acting on behalf of Sedgewall to ensure that they behave in an ethical manner,
  • Support employees who, in good faith, raise questions or concerns about ethical issues within the company.

Personal Responsibility

Everyone who works for Sedgewall has a responsibility to comply with the letter and the spirit of this policy, and to bring to the attention of management any suspected breach of the policy by another member of staff. In considering whether to speak up about a suspected breach, employees should ask themselves the simple questions:-

  • Is the action legal?
  • Does it comply with the this Policy?
  • Is it in line with Sedgewalls values?
  • Does it expose the company to unacceptable risk?
  • Does it match the commitments and guarantees that we have made to others?
  • How would it look if reported in the media?
  • Does it feel right?

As well as compliance with the policy, company employees are expected to exercise good judgement and common sense, so that their actions never jeopardise the reputation of the company as a responsible business.

D Griffith

General Manager

(Feb 2018)