ANTI-BRIBERY AND CORRUPTION POLICY
TFS Facilities Services 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 TFS Facilities Services Ltd’s position on preventing and prohibiting bribery and corruption in accordance with the Bribery Act 2010 (‘The Act’).
The Act came into force on 1st July 2011 and created a framework of five criminal offences;
- Giving, promising, and offering a bribe
- Agreeing to receive or accept a bribe
- Bribing a foreign official
- Failure of commercial organisations to prevent briber
- A senior officer of a commercial organisation consenting to or conniving in an act of bribery
The Act can be viewed using the following link:
http://www.legislation.gov.uk/ukpga/2010/23/contents
Policy Objective
TFS Facilities Services Ltd Anti Bribery and Corruption Policy (‘the Policy) sets out the key Anti-Bribery and Corruption principles which TFS Facilities Services Ltd is committed to.
Policy Scope
TFS Facilities Services Ltd employees, contractors and suppliers must comply with the Policy. The Policy extends to TFS Facilities Services Ltd having proportional procedures to ensure that all service providers (including contractors and suppliers) comply with TFS Facilities Services Ltd’s anti bribery and corruption policies. It is essential that TFS Facilities Services Ltd conduct an effective process of due diligence prior to entering into significant 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 TFS Facilities Services Ltd.
TFS Facilities Services Ltd 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.
TFS Facilities Services Ltd 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 TFS Facilities Services Ltd 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 TFS Facilities Services Ltd becoming 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.
Any concerns in relation to a breach of the Policy should be reported in one of the following ways.
- Your Line Manager
- Director of HR
- A Confidential and Anonymous Whistleblowing helpline.
Implementation, Monitoring and Compliance
TFS Facilities Services Ltd will conduct risk assessments across its business on a regular basis and where relevant will identify employees or officers of TFS Facilities Services Ltd who are in positions where they may be exposed to bribery.
Further information and training on the Act and what it means for TFS Facilities Services Ltd will be issued to those bribery risk areas identified in the risk assessment. This training will be mandatory for those individuals identified in these risk areas.
Further information and guidance
This policy sets out the key principles which TFS Facilities Services Ltd must adhere to. Further relevant information and guidance about this policy can be found in the UK Ministry of Justice website:
Name: Anthony Gayle Position: Managing Director
Signed: Date: 13.01.2022
Review Date: 12.01.2023