Anti-Bribery & Anti-Corruption Policy

Anti-Bribery & Anti-Corruption Policy

Last updated 20 May 2022


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

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

Scope is committed to conducting business ethically and honestly, and is committed to implementing and enforcing systems that ensure bribery is prevented. 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 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 recognises that bribery and corruption are punishable by up to 10 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. With this in mind, we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

Who is covered by the policy?

This anti-bribery policy applies to all employees (whether temporary, fixed-term or permanent), consultants, sub-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 Directors.In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It relates to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisors and government and public bodies – this includes their advisors, representatives and officials, politicians and public parties.

Definition of Bribery

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting or soliciting something of value or an advantage to induce or influence an action or decision.A bribe refers to any inducement, reward or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage.Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and accept it, they are also breaking the law.Bribery is illegal. Employees must not engage in any form of bribery, whether directly, passively (as described above), or through a third party (such as an agent or distributor). They must not accept bribes to any degree, and if they are uncertain about whether something is a bribe, or a gift or an act of hospitality, they must seek further advice from the management team.

What is and is not acceptable

This section of the policy refers to 4 areas:

  • Gifts and hospitality
  • Facilitation payments
  • Political contributions
  • Charitable contributions

5.1 Gifts and Hospitality 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:

  • 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.
  • It is not made with the suggestion that a return favour is expected.
  • It complies with local law.
  • It is given in the name of the company, not an individual’s name.
  • It does not include cash or a cash equivalent (eg a voucher or gift certificate).
  • It is appropriate for the circumstances (eg giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
  • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
  • It is given/received openly, not secretly.
  • It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
  • It is not above a certain excessive value, as pre-determined by the company’s management team (usually in excess of £100).
  • It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s management team.

As good practice, gifts given and received should always be disclosed to the management team. Gifts from suppliers should always be disclosed.

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

5.2 Facilitation Payments and Kickbacks 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. does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

5.3 Political Contributions 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.

5.4 Charitable Contributions 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.

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

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 management team.

Employee Responsibilities

As an employee of, 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.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.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 management team.If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. A Senior Manager has the right to terminate a contractual relationship with an employee or sub-contractor if they breach this anti-bribery policy.

What happens if I need to raise a concern?

This section of the policy covers 3 areas:

  • How to raise a concern
  • What to do if you are a victim of bribery or corruption
  • Protection

7.1 How To Raise A Concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to, you are encouraged to raise your concerns at as early a stage as possible. You are uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to a member of the management team.

7.2 What To Do If You Are Victim Of Bribery Or Corruption

You must tell a member of the management team as soon as possible if you are bribed 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.


If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, understands that you may feel worried about potential repercussions. will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were 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.Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.If you have reason to believe you have been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform the management team.

Training and communication

All new employees and sub-contractors of will be provided with this policy as part of the induction process. The policy will also be made available on the employee intranet and the sub-contractor anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners and any third-parties at the outset of business relations, and as appropriate thereafter.

Record keeping 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 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.

Monitoring and reviewing’s management team 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.Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.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. Related policies and documents.

Contacting Us

We welcome any queries, comments or requests you may have regarding this Policy. Please do not hesitate to contact us at: or 0808 2524702

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