Anti-Bribery & Corruption Policy

Policy Statement

Brassart supports the 2010 Bribery Act in both principle and spirit. We expect all of our employees to behave with honesty, integrity and fairness in all their business dealings with both other companies and with private customers. All staff will display professional and ethical conduct in all business dealings and will be entitled to expect the same response from our business partners and suppliers.

The Company will not tolerate the use of bribery or corruption in any form and will adopt a ‘zero tolerance’ approach to any person who breaches this policy. In this context, bribery is the giving, receiving, offering, providing, requesting or accepting financial or other benefits in order to seek to induce a person to give improper assistance or to influence the outcome of a business negotiation or to assist in obtaining or retaining a business advantage. Bribery also includes payments made to Government or public officials to speed up administrative processes. Corruption is the mis-use of entrusted power or a breach of duty for personal gain.

Application

In effect this means that the Company and its employees will never seek, accept or give a bribe, facilitation payment, kickback or other improper payment in money or in kind.

We will always operate in a legal and transparent manner. Should any member of staff doubt if an action is against the Act they should consider how that action would look to a third party. If a doubt still exists, they should talk to a senior staff member.

Our Policy

Through the issuing of this statement to all staff members and giving more support to those employees who may need it, we will ensure that:

  1. We do not, directly or indirectly, offer, promise, give, accept or demand a bribe or other undue advantage (including excessive gifts, hospitality or discounts) in order to retain or obtain business or to gain any other improper advantage.
  2. We do not offer, nor will we respond to demands, for illegal or illicit payments to be made to any agent, public official or employee of any business partner or associate with whom we conduct business.
  3. We employ and remunerate agents and other third parties only for legitimate services and only in an open and transparent manner.
  4. We promote employee awareness of and compliance with the Companies policy with regards to bribery and corruption by dissemination and training policies at induction and subsequently as necessary.
  5. We adopt management control systems that make bribery and corruption difficult and adopt stringent financial, accounting and auditing practices that make ‘off the book’ accounts and the production of ‘ghost’ documents difficult.
  6. We do not make any contributions to any candidate for public office, political parties or other organisations that are illegal or inappropriate.
  7. We endeavor to raise awareness of the need to eliminate bribery and corruption by the production of this document and its dissemination to relevant parties.