Actikem Anti-Bribery and Corruption Policy

Actikem Ltd is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. This policy sets out Actikem’s position on preventing and prohibiting bribery and corruption in accordance with the Bribery Act 2010 (‘The Act’).

Policy Objective

The Actikem Anti-Bribery and Corruption Policy (‘the Policy’) sets out the key Anti-Bribery and Corruption principles which Actikem is committed to.

Policy Scope

All Actikem employees, contractors and suppliers must comply with the Policy and it extends to all of our business dealing and transactions in the UK and in all countries in which Actikem operate. The Policy extends to Actikem having proportionate procedures to ensure that all service providers (including contractors and suppliers) comply with Actikem’s anti-bribery and corruption policies. It is essential that Actikem conduct an effective process of due diligence prior to entering into significant business relationships and that we keep a record of this process.

Any breach of the Policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of Actikem.

Actikem does not tolerate, permit, or engage in bribery, corruption, or improper payments of any kind in our business dealings, anywhere in the world, both with public officials and people in the private sector. Ethical behaviour is in the long term interests of our company and is a key value in our business.

Actikem is committed to the following key Anti Bribery and Corruption principles:

 

  • We will carry out business fairly, honestly and openly.
  • We will not give or offer any money, gift, hospitality or other advantage to any person carrying out a business or public role, or to a third party associated with that person, to get them to do something improper.
  • We will not give or offer any money, gift, hospitality or other advantages to any foreign public official with the intention of influencing them to our business advantage.
  • We will not use intermediaries or contractors for the purpose of committing acts of bribery.
  • We do not allow employees to accept money, gifts, hospitality and other advantages from business associates, actual or potential suppliers, or service providers which are intended to influence a business decision or transaction in some improper way.
  • Any employee found to be in breach of these principles will face disciplinary action.
  • No employee will suffer demotion, penalty, or other adverse consequence for refusing to pay bribes, even if it may result in Actikem losing business.
  • We will avoid doing business with others who do not commit to conducting business without bribery.
  • We are committed to a programme to counter the risk of Actikem involved in bribery. We will have adequate procedures in place to ensure that all employees understand the implications of the Act and our procedures. We will have appropriate mechanisms in place to record any problems.

Actikem will conduct risk assessments across its businesses on a regular basis and where relevant will identify employees or officers of Actikem who are in positions where they may be exposed to bribery.

Further information and training on the Act and what it means for Actikem will be issued to these bribery risk areas identified in the risk assessment.

General guidance will be cascaded through senior management and line managers and will be made available to all employees.

The Directors will monitor the adequacy of this Policy and associated processes and procedures on a regular basis.

Further information and guidance

This policy sets out the key principles which Actikem must adhere to. Further relevant information and guidance about this policy can be found in the UK Ministry of Justice website: