1. Policy Statement
WDC Agency Limited (the “Company”) is committed to conducting business with integrity and in compliance with the Bribery Act 2010. This policy outlines our responsibilities in observing and upholding our zero-tolerance position on bribery and corruption.
2. Purpose
The purpose of this policy is to:
– Set out the responsibilities of those working for us in observing and upholding our stance against bribery and corruption.
– Provide information and guidance on how to recognize and deal with bribery and corruption issues.
3. Scope
This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term, or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located.
4. What is Bribery?
Bribery involves the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action which is illegal or a breach of trust. A bribe does not actually have to take place – just promising to give a bribe or agreeing to receive one constitutes bribery.
5. Gifts and Hospitality
This policy does not prohibit giving or receiving promotional gifts of low value or normal and appropriate hospitality. However, any gift or hospitality:
– Should not be made with the intention of influencing a third party to obtain or retain business or a business advantage.
– Should not be made with the suggestion that a return favour is expected.
– Should be given in the name of the company, not in an individual’s name.
– Should comply with local law.
– Must be appropriate for the circumstances (e.g., giving small gifts around Christmas or as small thank yous to company business partners is acceptable).
– Must be recorded transparently in the Company’s gifts and hospitality register.
6. Facilitation Payments and Kickbacks
The Company does not accept and will not make any form of facilitation payments of any nature. We recognize that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We expect employees and third parties to avoid any activity that might lead to, or suggest, a facilitation payment will be made or accepted by us.
7. Compliance
Employees must ensure they read, understand, and comply with this policy. The prevention, detection, and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.
8. Reporting Violations
If anyone believes or suspects a violation of this policy has occurred or may occur in the future, they must notify their manager or report it in accordance with our Whistleblowing Policy.
9. Policy Review
The directors 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.
