Inaugural AI is committed to conducting all aspects of our business honestly and ethically at all times, and accordingly to implement and enforce effective systems to counter bribery within our business practices. Inaugural AI has a zero tolerance to bribery.
This Policy sets out how our business and its people can operate in accordance with the relevant legislation, the Bribery Act 2010 and all associated guidance, and maintain the highest possible standards of business practice.
This Policy applies to all individuals working at all levels including directors, employees (whether permanent, fixed term or temporary), consultants, contractors, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees wherever located.
2. What is a bribe?
A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Bribery Act 2010, namely:
Bribery does not have to involve cash or an actual payment exchanging hands and can take many forms such as a gift, lavish treatment during a business trip or tickets to an event. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
Bribery is illegal: breach of the relevant law is punishable for individuals by up to 10 years imprisonment, and if Inaugural AI is in breach of the law, we could face an unlimited fine and be excluded from tendering for certain contracts and face serious damage to our reputation.
3. The Inaugural AI Policy
We will not:
We will:
4. Your responsibilities
You must ensure that you read, understand and comply with this Policy at all times. Everyone working at or for Inaugural AI must work to prevent, detect and report bribery or any other form of corruption in the workplace. If you believe that this Policy has been breached, you must inform your manager as soon as possible.
Any employee who is found to have breached this Policy will face disciplinary action which could result in dismissal for gross misconduct.
We may immediately terminate our contractual relationships with other workers (i.e. consultants, contractors, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors or any other person associated with us if they breach this Policy without any liability or further obligation.
If you believe you have been the victim of corruption, are offered a bribe by a third party or are requested to make one, it is important that you tell your manager as soon as possible.
You must not:
If you are unsure whether your actions would be acceptable or not, please consult with a director before proceeding.
5. Gifts
This Policy does not prohibit receiving promotional gifts of a low value. This is normal and appropriate. All gifts, however, small, should be recorded. However, gifts with a value exceeding £25.00 may not be accepted without the approval of a director. Any gift offered and then refused because of its value must be reported to a director.
When giving or receiving a gift you must ensure that the gift 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 a business advantage, or in explicit or implicit exchange for favours or benefits. The gift must be given or received in our name, not your name and must be made openly and not secretly.
6. Hospitality
This Policy also does not prohibit normal and appropriate hospitality (given and received) to or from third parties, provided it falls within reasonable bounds of value and occurrence.
However, entertainment of third parties may only be undertaken by directors or by others if they have been given express authorisation by a director in writing. If you are invited to take part in a hospitality event by a third party, again, you must have the express authorisation by a director in writing before you accept.
7.Record Keeping
You must declare and keep a written record of all hospitality or gifts accepted or offered, with specific reference to the reason for expenditure. Your record should be readily available for review on request.
Strict accuracy and completeness should be maintained in relation to accounts, invoices and all other documents and records related to dealings with any third parties. No invoice or amount should be “off record”.
8. How to raise a concern
You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible opportunity. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your manager.
9. Protection
Anyone who refuses to accept or offer a bribe, or anyone who raises concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and 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 bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the managing director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be provided through contact with your manager.
10. Training and Communication
Training on this Policy can be requested via your manager at any time. Our zero-tolerance approach must be communicated to all operatives, agencies, suppliers, contractors and business partners at the outset of our business relationship.
11. Who is responsible for this Policy?
The Board of Directors has overall responsibility for ensuring this Policy complies with our legal and ethical obligations and that all those under our control comply with it. The managing director has primary and day to day responsibility for implementing this Policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this Policy and are given adequate and regular training on it.
12. Monitoring and review
The Board will monitor the effectiveness and review the implementation of this Policy regularly; considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.
You are invited to comment on this Policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the compliance manager.
Last updated Aug 2024