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Anti Bribery Policy.

1. Introduction 

It is Vault UK Group's policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption. 

Vault UK Group will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, Vault UK Group remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

 

2. Purpose 

The purpose of this policy is to set out our responsibilities, and of those working for Vault UK Group and/or our subsidiaries, in observing and upholding our position on bribery and corruption; and to provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues. 

It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years' imprisonment and/or a fine. As an employer if we fail to prevent bribery we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously.

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In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties. This policy does not form part of any employee's contract of employment and we may amend it at any time. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located. 

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3. Definitions 

Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage. 

Corruption is the abuse of entrusted power or position for private gain.

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4. What You Must Not Do 

It is not acceptable for you (or someone on your behalf) to: 

  • Give, promise to give, or offer, a payment, gift or excessive hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given; 

  • Give or accept a gift or excessive hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome; 

  • Accept a payment, gift or excessive hospitality from a third party that you know or suspect is offered with the expectation that it we will provide a business advantage for them or anyone else in return; 

  • Accept excessive hospitality from a third party that is unduly lavish or extravagant under the circumstances. 

  • Offer or accept a gift to or from government officials or representatives, or politicians or political parties; 

  • Threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; or 

  • Engage in any other activity that might lead to a breach of this policy. 

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5. Facilitation Payments and Kickbacks 

Vault UK Group do not make, and will not accept, facilitation payments or "kickbacks" of any kind. 

Facilitation payments, also known as "back-handers" or "grease payments", are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official).  Kickbacks are typically payments made in return for a business favour or advantage. 

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You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with your line manager or a director of the Group.

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6. Gifts, Hospitality and Expenses 

This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of: 

  • Establishing or maintaining good business relationships; 

  • Improving or maintaining our image or reputation; or 

  • Marketing or presenting our products and/or services effectively. 

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The giving and accepting of gifts is allowed if the following requirements are met: 

  • It is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits; 

  • It is given in our name, not in your name; 

  • It does not include cash or a cash equivalent (such as gift certificates or vouchers); 

  • It is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas; 

  • It is given openly, not secretly; and 

  • It complies with any applicable local law. 

 

Promotional gifts of low value such as branded stationery to or from existing customers, suppliers and business partners will usually be acceptable. Reimbursing a third party's expenses, or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable. 

 

We appreciate that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. The intention behind it should always be considered.

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7. Record-Keeping 

Vault UK Group requires the maintaining of financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties. A declaration and written record of all hospitality or gifts given or received must be kept, which will be subject to managerial review. All staff must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.

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8. How to Raise a Concern 

If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your line manager or a director of the Group as soon as possible.

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9. Breaches of this Policy 

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy. 

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Last Reviewed: 05 October 2023

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