This policy: (a) outlines our responsibilities, and of those working for or with us, in observing and upholding our position on bribery and corruption; (b) sets out procedures to supporting this policy and (c) provide information and guidance to those working for us on how to recognise and deal with bribery and corruption.
2. Policy Statement
2.1 Conduct of Business: The policy of Buglass Energy Advisory Limited is to conduct our business in an honest and ethical manner. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships and implementing and enforcing effective systems to counter bribery. That commitment means that we do not tolerate bribery and corruption.
2.2 Laws: Buglass Energy Advisory Limited will uphold all laws which apply to us concerning bribery and corruption, including the Bribery Act 2010.
3.1 Individuals: This policy applies to all individuals working for Buglass Energy Advisory Limited .
3.2 Business Partners: We intend to make clients, contractors, consultants or suppliers with whom we work aware of this policy as it applies in our dealings with them. Where appropriate, we will encourage them to adopt a similar policy, and adequate procedures, to prevent bribery or, if appropriate, discuss with them how this policy dovetails with any similar policy they have established for their business.
4.1 Policy: Buglass Energy Advisory Limited does not permit any form of bribery or corruption. By bribery, we mean where one person offers, pays, seeks or accepts a payment, gift, favour, or a financial or other advantage from another to influence a business outcome improperly, or to induce or reward improper conduct.
4.2 Conduct: Individuals who work for Buglass Energy Advisory Limited :
(a) must not offer, pay, make, seek or accept a personal payment, gift or favour in return for favourable treatment or to gain any improper business advantage;
(b) must follow the anti-bribery and corruption laws which apply to Buglass Energy Advisory Limited and that individual;
(c) will be, if found to have acted in contravention of this policy or its principles, subject to disciplinary action, including summary dismissal where the breach amounts to gross misconduct, if found to have acted in contravention of this policy or its principles.
(d) must ensure that people who work for and with you understand bribery and corruption is unacceptable;
(e) must comply with Buglass Energy Advisory Limited’s procedures for the prevention of bribery and corruption.
5. Gifts and hospitality
5.1 Gifts: Normal and appropriate gifts may be given to, or received from, third parties.
5.2 Hospitality: Normal and appropriate hospitality may be given to, or received from, third parties.
5.3 Normal and Appropriate: The test to be applied is whether, in all the circumstances, the gift or hospitality is reasonable and proportionate to the business being transacted. The intention behind the gift should always be considered. The following factors are relevant when applying the test:
(a) the gift or hospitality is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
(b) it is given in the name of Buglass Energy Advisory Limited , and not in an individual’s name;
(c) it does not include cash or a cash equivalent (such as gift certificates or vouchers);
(d) it is of an appropriate type and value and given at an appropriate time; and
(e) it is given openly, not secretly.
5.4 Threshold Value: Any gifts, hospitality given or received with a value in excess of £50, must be declared and recorded in writing. For any gift received, a sensible estimate of the value may be made by the individual receiving it.
6.1 Establishing Adequate Procedures: Buglass Energy Advisory Limited will establish adequate procedures to prevent bribery and corruption in its business and to implement this Anti-Bribery Policy.
6.2 Implementing Procedures:
(a) Communication – We will communicate this policy and relevant guidance to all individuals working for Buglass Energy Advisory Limited and to our clients, suppliers, contractors and business partners and wider stakeholders.
(b) Training – We will ensure that those within the scope of the policy receive training appropriate to their activities and the associated risks.
(c) Books and records – We will maintain adequate books and records which properly and fairly document all financial transactions. We will maintain written evidence to record compliance with this policy.
(d) Business relationships – We will require that our business partners –including clients, contractors, suppliers and, agents – have in place adequate procedures to combat bribery.
(e) Conflicts of interest – We will address conflicts of interest through discussions with clients.
(f) Gifts and hospitality – We will address the risks created by gifts and hospitality by establishing implementing procedures to implement the policy set out in paragraph 5 of this Policy.
(g) Government officials – We will implement procedures appropriate to our dealings with government officials, political parties and related persons or organisations.
7.1 Corrupt practices: Each individual must report any actual, potential or suspected corruption by any individual or organisation with whom Buglass Energy Advisory Limited does business.
7.2 Bribery: Each individual must report any request for an improper payment, or any indication that a person might be making corrupt payments or that a person has an intention or plan to violate this policy.
7.3 Investigation: If any instance of bribery or corruption is identified, an investigation will take place under the guidance of a director assisted with appropriate expert advice.
7.4 Support: we will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We 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 act of bribery or other corruption has taken place, or may take place in the future.
8. Monitoring and review
The Directors of Buglass Energy Advisory Limited will convene a committee annually to review compliance with this Anti-Bribery Policy and assess whether any changes are required to the policy or its implementation in light of experience and, in particular, if an instance of bribery comes to light.
(Version 1.2 - Last updated November 2015)