1.1 At W H Kirkwood Ltd we are committed to conducting business with honesty, integrity, and transparency. We take a zero–tolerance approach to bribery and corruption and expect the highest ethical standards from all employees and business partners.
1.2 Any employee who violates this policy will face disciplinary action, which may include dismissal for gross misconduct. Non–employees, including contractors, may have their contracts terminated with immediate effect. 1.3 This policy does not form part of any employee’s contract of employment, and we reserve the right to amend it at any time. It will be reviewed regularly to ensure effectiveness and compliance with relevant laws and regulations.
2. Who Must Comply with This Policy?
2.1 This policy applies to all individuals working for or on behalf of W H Kirkwood Ltd, including:
Employees (at all levels)
Directors
Agency workers
Subcontractors, and external consultants
3. What is Bribery?
3.1 A bribe is any financial or non–financial inducement or reward intended to improperly influence a decision, gain an unfair business advantage, or encourage unethical behaviour. This can include:
Money, gifts, or loans
Hospitality, services, or discounts
Business contracts or other benefits
3.2 Bribery includes:
Offering, giving, or promising a bribe
Requesting, agreeing to receive, or accepting a bribe
3.3 All forms of bribery are strictly prohibited. If you are unsure whether a particular act constitutes bribery, consult your Manager.
3.4 Specifically, you must NOT:
Offer or give payments, gifts, or hospitality in exchange for business advantages or as a reward for securing business.
Accept any gifts, payments, or favours that may improperly influence business decisions.
Make facilitation payments to expedite routine processes.
3.5 Retaliation against any individual who refuses to engage in bribery or reports concerns is strictly prohibited.
4. Gifts and Hospitality
4.1 This policy does not prohibit the exchange of modest and appropriate hospitality intended to build relationships, maintain a positive company image, or promote our services.
4.2 However, gifts or hospitality must not:
Be excessive, lavish, or frequent.
Include cash or cash equivalents (such as vouchers).
Be given during contract negotiations or tender processes if it could be seen as an inducement.
4.3 Gifts must always be reasonable and transparent. Branded promotional items of low value (e.g., stationery, cups) are generally acceptable.
5. Record-Keeping
5.1 Employees must maintain accurate records of all gifts and hospitality given or received.
5.2 All financial records, invoices, and transactions must be recorded with full accuracy. Off–the–books accounts or false records to conceal improper payments are strictly prohibited.
6. How to Raise a Concern
6.1 If you are:
Offered or asked to give a bribe
Aware of or suspect bribery or corruption within the company
You must immediately report it to your Manager. Confidentiality and protection from retaliation will be ensured.