INTRODUCTION

Bribery is, in the conduct of Diligence Security Solutions business, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust.

Bribery is a criminal offence. Diligence Security Solutions prohibits any form of bribery. We require compliance from everyone connected with our business. Abiding and promoting the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero-tolerance attitude towards corrupt activities of any kind whether committed by our employees or by third parties acting for or on behalf of Diligence Security Solutions.

OFFENCES

It is a criminal offence to:

  • offer a bribe
  • accept a bribe
  • bribe a foreign official
  • as a commercial organisation, failing to prevent a bribe.

You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine.

PURPOSE

The purpose of this policy is to convey to all employees and interested parties of Diligence Security Solutions the rules of the Organisation in relation to our unequivocal stance towards the eradication of bribery and our commitment to ensuring that all of business is conducted its in a fair, professional and legal manner.

DEFINITIONS OF BRIBERY AND CORRUPTION

Corruption is the misuse of office or power for private gain. Bribery is a form of corruption which means in the course of business:

  • Giving or receiving money, gifts, meals, entertainment or anything else of value.
  • As an inducement to a person to do something which is dishonest or illegal.

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SCOPE

This policy applies to all employees of Diligence Security Solutions regardless of seniority or site. It also extends to anyone working for or on our behalf including those engaged by us on a self-employed basis or an agency arrangement.

We will encourage the application of this policy where our business involves the use of third parties such as suppliers or contractors. 

POLICY

It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement to or from any person or organisation in order to gain commercial, contractual or regulatory advantage for the Organisation or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

It is also prohibited to act in the above manner in order to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.

If you are offered a bribe or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact Head Office so that action can be taken if considered necessary. You may be asked to give a written account of events.

If you as an employee or person working on our behalf suspect that an act of bribery or attempted bribery has taken place, even if you are not personally involved, you are expected to report this to Head Office. You may be asked to give a written account of events. 

Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.

Diligence Security Solutions will ensure that all of its transactions including any sponsorship or donations given to charity, are made transparently and legitimately.  

All actual or suspected breaches of this policy will be dealt with extremely seriously and a thorough investigation will be conducted should any instances arise. 

We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, an agency worker, contractor etc.

Staff are reminded of the Whistleblowing Policy which is available in the Employee Handbook, or upon request.

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GIFTS AND HOSPITALITY

We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy. 

Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context) services or loans given or received as a mark of friendship or appreciation.

Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present.

No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from Diligence Security Solutions Directors.

 Similarly, no gift nor offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from Diligence Security Solutions Directors.

A record will be made of every instance in which gifts or hospitality are given or received. 

As the law is constantly changing, this policy is subject to review and as such Diligence reserves the right to amend this policy without prior notice.

For and on behalf of Diligence Security Solutions Limited