Anti-Bribery and Anti-Corruption Policy

Anti-Bribery & Anti-Corruption Policy
PeopleMaps Ltd

Contents

1. What does your policy cover? …………………………………………………………………….3
2. Policy statement …………………………………………………………………………………………3
3. Who is covered by the policy?………………………………………………………………… 3-4
4. Definition of bribery …………………………………………………………………………………..4
5. What is and what is not acceptable ……………………………………………………….. 4-6
a. Gifts and hospitality…………………………………………………………………….4-5
b. Facilitation payments and kickbacks …………………………………………..5-6
c. Political contributions ……………………………………………………………………..6
d. Charitable contributions …………………………………………………………………6
6. Employee responsibilities …………………………………………………………………………..6
7. What happens if I need to raise a concern ……………………………………………… 7-8
a. How to raise a concern ………………………………………………………………….7
b. What to do if you area victim of bribery or corruption ………………..7
c. Protection ………………………………………………………………………………….7-8
8. Training and communication………………………………………………………………………8
9. Record keeping……………………………………………………………………………………………8
10. Monitoring and reviewing…………………………………………………………………………..8

1. What does your policy cover?

1.1 This anti-bribery policy exists to set out the responsibilities of PeopleMaps Ltd
and those who work for us in regards to observing and upholding our zero-tolerance
position on bribery and corruption.

1.2 It also exists to act as a source of information and guidance for those working for
PeopleMaps Ltd . It helps them recognise and deal with bribery and corruption
issues, as well as understand their responsibilities.

2. Policy statement

2.1 PeopleMaps Ltd is committed to conducting business in an ethical and
honest manner, and is committed to implementing and enforcing systems that ensure
bribery is prevented. PeopleMaps Ltd has zero-tolerance for bribery and
corrupt activities. We are committed to acting professionally, fairly, and with integrity in all
business dealings and relationships, wherever in the country we operate.

2.2 PeopleMaps Ltd will constantly uphold all laws relating to anti-bribery and
corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK,
including the Bribery Act 2010, in regards to our conduct both at home and abroad.

2.3 PeopleMaps Ltd recognises that bribery and corruption are punishable by
up to ten years of imprisonment and a fine. If our company is discovered to have taken part
in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering
for public contracts, and face serious damage to our reputation. It is with this in mind
that we commit to preventing bribery and corruption in our business, and take our legal
responsibilities seriously.

3. Who is covered by the policy?

3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or
permanent), consultants, contractors, trainees, seconded staff, home workers, casual
workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons
associated with us (including third parties), or any of our subsidiaries or their employees,
no matter where they are located (within or outside of the UK). The policy also applies to
Officers, Trustees, Board, and/or Committee members at any level.

3.2 In the context of this policy, third-party refers to any individual or organisation our
company meets and works with. It refers to actual and potential clients, customers,
suppliers, distributors, business contacts, agents, advisers, and government and public
bodies – this includes their advisors, representatives and officials, politicians, and public
parties.

3.3 Any arrangements our company makes with a third party is subject to clear contractual
terms, including specific provisions that require the third party to comply with minimum
standards and procedures relating to anti-bribery and corruption.

4. Definition of bribery

4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving,
accepting, or soliciting something of value or of an advantage so to induce or influence an
action or decision.

4.2 A bribe refers to any inducement, reward, or object/item of value offered to another
individual in order to gain commercial, contractual, regulatory, or personal advantage.

4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end
of a bribe and they accept it, they are also breaking the law.

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be
directly, passively (as described above), or through a third party (such as an agent or
distributor). They must not bribe a foreign public official anywhere in the world. They must
not accept bribes in any degree and if they are uncertain about whether something is
a bribe or a gift or act of hospitality, they must seek further advice from the company’s
compliance manager.

5. What is and what is NOT acceptable

5.1 This section of the policy refers to 4 areas:
• Gifts and hospitality.
• Facilitation payments.
• Political contributions.
• Charitable contributions.

5.2 Gifts and hospitality
PeopleMaps Ltd accepts normal and appropriate gestures of hospitality and
goodwill (whether given to/received from third parties) so long as the giving or receiving of
gifts meets the following requirements:

a. It is not made with the intention of influencing the party to whom it is being
given, to obtain or reward the retention of a business or a business advantage,
or as an explicit or implicit exchange for favours or benefits.
b. It is not made with the suggestion that a return favour is expected.
c. It is in compliance with local law.
d. It is given in the name of the company, not in an individual’s name.
e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas
or as a small thank you to a company for helping with a large project upon
completion).
g. It is of an appropriate type and value and given at an appropriate time, taking
into account the reason for the gift.

h. It is given/received openly, not secretly.
i. It is not selectively given to a key, influential person, clearly with the intention
of directly influencing them.
j. It is not above a certain excessive value, as pre-determined by the company’s
compliance manager (usually in excess of £100).
k. It is not offer to, or accepted from, a government official or representative or
politician or political party, without the prior approval of the company’s
compliance manager.

5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual
of a certain religion/culture who may take offence), the gift may be accepted so long as it is
declared to the compliance manager, who will assess the circumstances.

5.4 PeopleMaps Ltd recognises that the practice of giving and receiving
business gifts varies between countries, regions, cultures, and religions, so definitions of
what is acceptable and not acceptable will inevitably differ for each.

5.5 As good practice, gifts given and received should always be disclosed to the compliance
manager. Gifts from suppliers should always be disclosed.

5.6 The intention behind a gift being given/received should always be considered. If there is
any uncertainty, the advice of the compliance manager should be sought.

5.7 Facilitation Payments and Kickbacks
PeopleMaps Ltd does not accept and will not make any form of facilitation
payments of any nature. We recognise that facilitation payments are a form of bribery
that involves expediting or facilitating the performance of a public official for a routine
governmental action. We recognise that they tend to be made by low level officials with the
intention of securing or speeding up the performance of a certain duty or action.

5.8 PeopleMaps Ltd does not allow kickbacks to be made or accepted. We
recognise that kickbacks are typically made in exchange for a business favour or advantage.

5.9 PeopleMaps Ltd recognises that, despite our strict policy on facilitation
payments and kickbacks, employees may face a situation where avoiding a facilitation
payment or kickback may put their/their family’s personal security at risk. Under these
circumstances, the following steps must be taken:

a. Keep any amount to the minimum.
b. Ask for a receipt, detailing the amount and reason for the payment.
c. Create a record concerning the payment.
d. Report this incident to your line manager.

5.10 Political Contributions
PeopleMaps Ltd will not make donations, whether in cash, kind, or by any
other means, to support any political parties or candidates. We recognise this may be
perceived as an attempt to gain an improper business advantage.

5.11 Charitable Contributions
PeopleMaps Ltd accepts (and indeed encourages) the act of donating to
charities – whether through services, knowledge, time, or direct financial contributions (cash
or otherwise) – and agrees to disclose all charitable contributions it makes.

5.12 Employees must be careful to ensure that charitable contributions are not used to
facilitate and conceal acts of bribery.

5.13 We will ensure that all charitable donations made are legal and ethical under local
laws and practices, and that donations are not offered/made without the approval of the
compliance manager.

6. Employee Responsibilities

6.1 As an employee of PeopleMaps Ltd , you must ensure that you read,
understand, and comply with the information contained within this policy, and with any
training or other anti-bribery and corruption information you are given.

6.2 All employees and those under our control are equally responsible for the prevention,
detection, and reporting of bribery and other forms of corruption. They are required to avoid
any activities that could lead to, or imply, a breach of this anti-bribery policy.

6.3 If you have reason to believe or suspect that an instance of bribery or corruption has
occurred or will occur in the future that breaches this policy, you must notify the compliance
manager.

6.4 If any employee breaches this policy, they will face disciplinary action and could face
dismissal for gross misconduct. PeopleMaps Ltd has the right to terminate a
contractual relationship with an employee if they breach this anti-bribery policy.

7. What happens if I need to raise a concern?

7.1 This section of the policy covers 3 areas:
a. How to raise a concern.
b. What to do if you are a victim of bribery or corruption.
c. Protection.

7.2 How to raise a concern
If you suspect that there is an instance of bribery or corrupt activities occurring in relation
to PeopleMaps Ltd , you are encouraged to raise your concerns at as early
a stage as possible. If you’re uncertain about whether a certain action or behaviour can be
considered bribery or corruption, you should speak to your line manager, the compliance
manager, the director, or the Head of Governance and Legal.

7.3 PeopleMaps Ltd will familiarise all employees with its whistleblowing
procedures so employees can vocalise their concerns swiftly and confidentially.

7.4 What to do if you are a victim of bribery or corruption
You must tell your compliance manager as soon as possible if you are offered a bribe by
anyone, if you are asked to make one, if you suspect that you may be bribed or asked to
make a bribe in the near future, or if you have reason to believe that you are a victim of
another corrupt activity.

7.5 Protection
If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of
bribery or corruption, PeopleMaps Ltd understands that you may feel worried
about potential repercussions. PeopleMaps Ltd will support anyone who raises
concerns in good faith under this policy, even if investigation finds that they were mistaken.

7.6 PeopleMaps Ltd will ensure that no one suffers any detrimental treatment
as a result of refusing to accept or offer a bribe or other corrupt activities or because they
reported a concern relating to potential act(s) of bribery or corruption.

7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable
treatment in relation to the concern the individual raised.

7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a
concern or refusal to accept a bribe, you should inform your line manager or the compliance
manager immediately.

8. Training and communication

8.1 PeopleMaps Ltd will provide training on this policy as part of the induction
process for all new employees. Employees will also receive regular, relevant training on how
to adhere to this policy, and will be asked annually to formally accept that they will comply
with this policy.

8.2 PeopleMaps Ltd ’s anti-bribery and corruption policy and zero-tolerance
attitude will be clearly communicated to all suppliers, contractors, business partners, and
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any third-parties at the outset of business relations, and as appropriate thereafter.

8.3 PeopleMaps Ltd will provide relevant anti-bribery and corruption training
to employees etc. where we feel their knowledge of how to comply with the Bribery Act
needs to be enhanced. As good practice, all businesses should provide their employees with
anti-bribery training where there is a potential risk of facing bribery or corruption during
work activities.

9. Record keeping

9.1 PeopleMaps Ltd will keep detailed and accurate financial records, and will
have appropriate internal controls in place to act as evidence for all payments made. We will
declare and keep a written record of the amount and reason for hospitality or gifts accepted
and given, and understand that gifts and acts of hospitality are subject to managerial review.

10. Monitoring and reviewing

10.1 PeopleMaps Ltd ’s compliance manager is responsible for monitoring the
effectiveness of this policy and will review the implementation of it on a regular basis. They
will assess its suitability, adequacy, and effectiveness.

10.2 Internal control systems and procedures designed to prevent bribery and corruption are
subject to regular audits to ensure that they are effective in practice.

10.3 Any need for improvements will be applied as soon as possible. Employees are
encouraged to offer their feedback on this policy if they have any suggestions for how it may
be improved. Feedback of this nature should be addressed to the compliance manager.

10.4 This policy does not form part of an employee’s contract of employment and
PeopleMaps Ltd may amend it at any time so to improve its effectiveness at
combating bribery and corruption.