Anti-bribery and corruption policy
1. Our position
We do not tolerate bribery or corruption in any form. We comply with the UK Bribery Act 2010 in everything we do, in the UK and in every country we trade with. The Act applies to our conduct worldwide.
2. Who this policy applies to
Our directors and employees, and anyone who works for us or on our behalf, including contractors, agents and representatives.
3. What is not allowed
- Offering, promising or giving anything of value to influence someone to act improperly, or to win or keep business.
- Asking for or accepting anything of value in return for acting improperly.
- Bribing a public official, in the UK or abroad, including customs and port officials.
- Facilitation payments: small unofficial payments to speed up routine actions, such as clearing goods through customs. We do not make them, even where they are common practice.
- Using an agent, freight forwarder, customs broker or anyone else to do any of the above on our behalf.
If someone demands a payment under threat to a person's safety, keep yourself safe, then report it to a director straight away.
4. Gifts and hospitality
Modest gifts and hospitality are a normal part of building relationships. They are allowed if they are reasonable, given openly, and not meant to influence a decision.
- Never give or accept cash, or cash equivalents such as vouchers.
- Record any gift or hospitality given or received worth more than £100 in our gifts and hospitality register.
- Get a director's approval before giving anything to a public official.
5. Working with third parties
Before we work with agents, freight forwarders, customs brokers or distributors, we check who they are. We pay only for genuine services, at a fair price, against a proper invoice. We include anti-bribery terms in our agreements with them.
6. Donations
We do not make political donations. Charitable donations need a director's approval and are recorded.
7. Accurate records
We keep accurate books and records of all payments, gifts and hospitality. We never keep "off the books" accounts.
8. Raising a concern
If you are asked for a bribe, are offered one, or suspect something is wrong, report it straight away to Peter Caplan, Director, or email admin@super7wholesale.com. We treat every report confidentially. No one will be treated unfairly for raising a concern in good faith.
9. Breaches
Anyone who breaks this policy may face disciplinary action, up to and including dismissal. We will end our relationship with any third party who breaks it.
10. Responsibility and review
The directors are responsible for this policy. We brief our team on it and review it every year.
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