BrandPipe Ltd

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Anti-Bribery and Corruption Policy ​

Including Gifts and Hospitality.

Version 2.4

This policy was last revised on 09 May 2024

Introduction ​

This policy is a constituent part of the wider BrandPipe Policy Framework (BPF) which sets out a framework of governance and accountability across BrandPipe.

BrandPipe has a strict zero tolerance policy towards bribery and corruption. This policy sets out the standards of behaviour we expect to minimise the risk of bribery, including our requirements for giving and receiving gifts and hospitality involving third parties.

The Policy ​

It is our policy to comply with the UK Bribery Act (2010) and all other bribery and corruption laws in the countries where we do business. Therefore:

  • individuals working for BrandPipe must never promise, offer or give a bribe;
  • they must never request or accept a bribe;
  • no individual will suffer demotion, penalty or other adverse consequences for refusing to pay or receive bribes, even if the refusal may result in the company losing business.

The Board has unanimously approved these principles. They apply in every country in which we operate, regardless of local customs and practices.

Who must comply ​

This policy applies to anyone who is employed by, or performs services for, or on behalf of, BrandPipe, anywhere in the world, in any capacity, including agency workers and contract staff.

Any persons employed by, or performing services for, or on behalf of, BrandPipe outside the UK must comply with local bribery and corruption laws as well as this policy.

BrandPipe may also require its business partners to comply with this policy and the associated guidance in all their dealings with or for BrandPipe.

What is bribery and corruption? ​

Bribery is promising, offering, giving, requesting or accepting, any advantage to encourage or reward improper behaviour.

  • An advantage can be any kind of benefit or anything of value, or perceived value to the person being offered the bribe (it does not have to involve money).
  • Improper behaviour is behaviour which is illegal, dishonest or a breach of duty. The bribe can be made direct or through a third person. It is still an offence to make a bribe, even if it is turned down or fails to have the intended effect.

Corruption is when you abuse your position with BrandPipe, or someone else abuses the power or position associated with their role, for personal benefit. This may arise from a conflict of interest between your private affairs and your work for BrandPipe.

Bribery and corruption may involve the public sector or private sector. However, extra care is needed when dealing with public officials (e.g. a government official or an employee of a state-owned company such as a national airline or postal operator) as the laws relating to them are stricter.

Facilitation payments (also known as ‘back-handers’ or ‘grease payments’), are typically small, unofficial payments or gifts made to public officials to perform, or speed up the performance of, their duties. Examples include unofficial payments to police officers or to accelerate customs clearance, health and safety checks or obtaining a permit, licence or visa. Facilitation payments are bribes and are illegal.

BrandPipe can be held responsible for bribery committed anywhere in the world by anyone performing services or acting on our behalf. This can include contract staff, business partners, suppliers, contractors and in some cases sub-contractors, third party intermediaries such as agents, and consultants, as well as any of our employees.

Compliance behaviours ​

Bribery and corruption ​

Everyone must follow standards of behaviour that minimise the risk of bribery for BrandPipe. All our dealings with public officials or private individuals and businesses must be open, transparent and conducted appropriately, following our business processes. This will ensure that no bribery or corruption takes place and avoid any appearance or suggestion that we are behaving improperly.

You must:

  • comply with this policy and any additional guidance issued by BrandPipe and your line manager;
  • take reasonable steps to reassure yourself that the agency, intermediary or other business partner you want to deal with is honest and can reasonably be expected to refrain from bribery;
  • keep proper, complete and accurate records;
  • always use approved business channels to make payments (never use cash or off-shore accounts);
  • complete all mandatory anti-bribery training courses you are asked to do, including refresher training;
  • report any concerns to the BrandPipe management team.

You must not:

  • promise, offer or give a bribe in any form, either direct or via someone else such as an agent or supplier;
  • request or accept a bribe in any form, either direct or via someone else;
  • make facilitation payments on behalf of BrandPipe or give the impression that BrandPipe will make such payments;
  • allow a private interest to influence your work, or fail to disclose a connection to a person or organisation we are doing business with;
  • use your official position with BrandPipe for your own advantage.

If in doubt about whether something might be a bribe or whether an action is appropriate, you must ask your line manager before going ahead.

Gifts and hospitality ​

If you offer or accept gifts, hospitality, entertainment, charitable donations or sponsorship to encourage or reward improper behaviour, this could be a bribe. This also includes any gifts or hospitality offered to your partner or relative, in connection with BrandPipe business.

You must:

  • follow company procedure for approving and recording gifts and hospitality, charitable donations and sponsorship;
  • advise your line manager immediately if you (or your partner or relative) are offered a gift, tip or hospitality and the donor suggests that something is expected in return. Do not accept the offer as this may be a bribe.

You must not:

  • request a gift from any individual or organisation with which BrandPipe has dealings;
  • offer or accept any gift, hospitality, charitable donation or sponsorship in order to influence a decision, or to conceal a bribe;
  • offer or accept any gift of cash or cash equivalents such as shares, gift cards or vouchers;
  • offer or accept any other gift or hospitality which is not allowed by BrandPipe;
  • make any form of political donation on behalf of BrandPipe, either financial or in kind (for example free use of business premises).

The key question to ask yourself is: “Do I expect the business relationship to be influenced improperly as a result of the gift, hospitality, donation or sponsorship in question?”

If the answer is yes, this may be a bribe, so don’t do it. If in doubt about whether you should offer or accept a gift or hospitality you must ask your line manager.

Consequences of non-compliance ​

Under UK law, bribery is a criminal offence. If you are convicted, you could go to prison for up to ten years or face unlimited fines. There are also serious penalties for BrandPipe, including unlimited fines, third party claims for loss, and being prevented from competing for public contracts. Your compliance with this policy and all applicable laws on anti-bribery and corruption is therefore essential to protect both you and BrandPipe.

You have a personal responsibility to follow this policy. Any breach will be treated as a disciplinary matter by BrandPipe and may result in disciplinary action (in accordance with local law if applicable) including termination of employment without notice. BrandPipe may report a breach to any appropriate authorities.

Where a business partner fails to comply with this policy BrandPipe may seek to terminate that business relationship.

Reporting concerns ​

BrandPipe is committed to ensuring that you can report any concerns in complete confidence. We take all reports very seriously and will investigate them. Retaliation, in any form, against someone who reports a concern is strictly prohibited.

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, anywhere within, or related to, BrandPipe, you must immediately report this to your line manager or a member of the Executive Team.

Monitoring and Evaluation ​

The Company Directors are responsible for reviewing the policy, related policies and procedures, reviewing incidents and recommending actions where necessary to strengthen controls. Where appropriate, the Company Directors will arrange training for lead officers responsible for investigating incidents.

The Directors may conduct periodic review on compliance with the Policy, recommending any actions needed to address risks and issues. The Directors are also responsible for meeting any reporting requirements of external regulatory bodies.

Company Policies & Procedures ​

This policy forms part of the BrandPipe Policy Framework and its underpinning policies, procedures and guidance which are published on the Company SharePoint site.

All current UK Legislation is published at http://www.legislation.gov.uk

UK Government guidance: https://www.gov.uk/anti-bribery-policy

Download ​

Further resources and materials

Download an offline version of this page from our secure Compliance Portal. Please note that the online version published in the Compliance Portal is always the most up-to-date.