Anti-Corruption and Bribery Policy
It is SDS Ltd.’s policy to conduct all 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 with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
We will uphold all laws relevant to countering bribery and corruption. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.
Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and if we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.
SDS Ltd have identified that the following are risks for our business, and these are addressed under Facilitation Payments and Kickbacks.
In this policy, “third party” means any individual or organisation you come into contact with during the course of your work or dealings for or with us, and includes actual and potential customers, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
Who is Covered by This Policy?
This policy applies to all individuals operating at all levels, including senior managers, directors, employees (whether permanent, fixed term or temporary), consultants, contractors, trainees, seconded employees, casual employees and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us or their employees, wherever located (collectively referred to as “employees” in this policy).
What is Bribery?
A bribe is an inducement or reward offered, promised, or provided to gain any commercial, contractual, regulatory, or personal advantage.
Receiving a Bribe
It is not acceptable for SDS Ltd employees to:
• give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given
• give, promise to give, or offer, a payment, gift or hospitality to a government official, agent, or representative to “facilitate” or expedite a routine procedure
• accept payment from a third party that they know, or suspect is offered with the expectation that it will obtain a business advantage for them
• accept a gift or hospitality from a third party if they know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return
• threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
• engage in any activity that might lead to a breach of this policy
Facilitation Payments and Kickbacks
SDS Ltd do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.
Kickbacks are typically payments made in return for a business favour or advantage. All employees must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by SDS Ltd.
Donations
SDS Ltd do not make contributions to political parties. SDS Ltd only make charitable donations that are legal and ethical. No donation must be offered or made without the prior approval of SDS Ltd management.
Record-keeping
SDS Ltd keep financial records and have appropriate internal controls in place which will evidence business reason for making payments to third parties.
All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as customers, suppliers, and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.
How to Raise a Concern
SDS encourage employees, partners, and clients to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with SDS Ltd Management by emailing accounts@sdsdrives.com.
Protection
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. SDS Ltd aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
SDS Ltd are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
Training and Communication
Training on this policy forms part of the induction process for all new and existing employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy. SDS Ltd.’s zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors, and business partners at the outset of SDS Ltd.’s business relationship with them and as appropriate thereafter.
