Published 09/07/2016 – V1.1 Reviewed 20/01/2025
ICT Reverse Anti-Corruption & Bribery Policy
1. About this policy
1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed
to acting professionally, fairly and with integrity in all our business dealings and relationships.
1.2 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches
this policy may have their contract terminated with immediate effect.
1.3 This policy does not form part of any employee’s contract of employment and we may amend it at any time. It will be reviewed regularly.
2. Who must comply with this policy?
2.1 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded
workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
3. What is bribery?
3.1 Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the
form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
3.2 Bribery includes offering, promising, giving, accepting or seeking a bribe.
3.3 All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager or the Compliance
Director.
3.4 Specifically, you must not:
- give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any
business received; - accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or
anyone else; - give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or
necessary procedure;
3.5 You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or
corruption.
4. Gifts and hospitality
4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships,
maintaining our image or reputation, or marketing our products and services.
4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any
4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include
cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.
4.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners
5. Record-keeping
5.1 You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or
payments to third parties in accordance with our expenses policy and record the reason for expenditure.
5.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and
completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
6. How to raise a concern
If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you
must notify your manager or the Compliance Director as soon as possible.
v1.0 Initial Issue 09/07/2016
v1.1 Reviewed 21/05/2018
V1.1 Reviewed 05/11/2019
V1.1 Reviewed 07/12/2020
V1.1 Reviewed 17/12/2021
V1.1 Reviewed 02/12/2022
V1.1 Reviewed 02/01/2024
V1.1 Reviewed 20/01/2025