Bribery and Corruption Policy

This policy explains the procedures through which Turvey Construction Limited can maintain its high ethical standards and protect its reputation against any allegations of bribery and corruption.  The Company will aim to create and maintain a trust-based and inclusive internal culture in which bribery and corruption, both direct and indirect, are not tolerated.

The policy applies to all Turvey Construction Limited employees, including any subsidiary in which it has a controlling interest as well as agency workers, consultants, contractors, clients or prospective clients.

If you fail for any reason to follow the rules set out in this document this may result in disciplinary action being taken against you which could result in your dismissal. It may also constitute a criminal matter for the individual concerned.

Bribery is the offer or receipt of any gift, loan, payment, reward or other advantage to or from any person as an encouragement to do something which is dishonest, illegal or a breach of trust, in the conduct of the Company’s business. 

Corruption is the misuse of entrusted power for private gain. 
To place this in context, you should be aware that if you engage in activities which are contrary to UK anti-bribery and corruption legislation, you could face up to 10 years in prison and/or an unlimited fine, and the Company could also be liable to an unlimited fine and Government sanction. 
This policy document is not regarded as exhaustive, but does give specific examples of situations and sets out the rules and procedures and which should be followed. 

You should at all times act in accordance with the following provisions:

• Behave honestly, be trustworthy and set a good example
• Use the resources of the Company in the best interests of the Company and do not misuse those resources
• Make a clear distinction between the interests of the Company and your private interests to avoid any conflict of interest, and if such conflict does arise you should report it immediately
• Ensure that any community support, sponsorship and charitable or political donations do not constitute bribery, and if in doubt you should consult the directors 
• Confidentially report all incidents, risks and issues which are contrary to this policy document
• Raise any issues regarding anti-bribery and corruption laws and the Company’s policies. Queries will be dealt with anonymously and a written response will be issued
• Do not offer or accept bribes.
• Do not offer money to any public officials in order to speed up service or gain improper advantage. This type of bribery is a ‘facilitation payment’ and is illegal. If you are faced with a demand for a facilitation payment you must actively resist the payment and inform the Company

Gifts, Entertainment, Hospitality and Expenses

The giving or receiving of these are acceptable provided they fall within reasonable bounds of value and occurrence.

Any gift received or given by an employee or representative of the Company must be reported to the Company and recorded.  This register will be reviewed regularly and the following criteria will be used to determine if the gifts, entertainment, hospitality or expenses are appropriate:

Made for the right reason: the gift or hospitality should be given clearly as an act of appreciation;
No obligation: the gift, hospitality or reimbursement of expense does not place the recipient under any obligation;
No expectations: expectations are not created in the giver or an associate of the giver nor have a higher importance attached to it by the giver than the recipient would place on such a transaction;
Made openly: if made secretly then the purpose will be suspect;
Accords with stakeholder perception: the transaction would not be viewed unfavourably by stakeholders if it were made known to them;
Reported and recorded: the gift, hospitality or expense should be recorded and reported to and recorded by management;
Reasonable value: the size of the gift is small; the value of the hospitality or reimbursed expense accords with general business practice;
Appropriate: the nature of the gift, hospitality or reimbursed expense is appropriate to the relationship and accords with general business practice;
Legality: it conforms to the laws of the country where it is made;
Conforms to the recipient’s rules: the gift, hospitality or reimbursement of expenses meets the rules or code of conduct of the receiving organisation;
Infrequent: such giving or receiving is not a regular happening between the giver and the recipient.

Definitions

Gifts are presents such as money, flowers, vouchers, goods, services or loans. Event and travel tickets given to you as an individual are also gifts when they are not to be used in a hosted business context. 

Hospitality includes invitations to hosted meals, receptions, social or sports events for business purposes. 

Expenses are the provision or reimbursement of travel and other related expenses incurred.

Internal Controls and Audits

To ensure company integrity, transparency and accountability it will maintain accurate books and records, available for inspection, which properly and fairly document all financial transactions.

Raising Concerns and Seeking Guidance

If you are at any time uncertain as to whether your actions will comply with this policy, you must seek guidance from the Company. 

If you are aware or suspect any Company employee, agency workers, consultants, contractor or client or prospective client you must raise your concerns by initiating the Company Whistle blowing procedure.

The UK anti-bribery and corruption legislation applies to all activities of a UK-based business no matter where they are carried out in the world. This policy therefore applies to ALL activities worldwide, whatever the local law, practice or custom may be. 

By complying with this policy document we aim to ensure that you and the Company will not at any time knowingly breach any relevant anti-bribery and corruption legislation and also that by adhering to the Policy the Company can demonstrate that it has adequate procedures in place to prevent such activity. 

You have an independent obligation to prevent bribery and corruption in the Company and to ensure that any interaction with public officials complies with this policy document and relevant laws.