Anti-Bribery Policy

1.        Policy Statement

Vision Training (North East) Limited values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. 

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 relationships and business dealings wherever we operate and to implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption. We remain bound by the laws of the UK, including the Bribery Act 2010.  Bribery and corruption are punishable for individuals by imprisonment and if the company is found to have taken part in corruption we could face fines and damage to our reputation. We therefore take our legal responsibilities very seriously.

The Company prohibits:

  • the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement

To or from

  • Any person or company, wherever they are situated and whether they are a public official or body or private person or company

By

  • Any individual employee, agent or other person or body acting on the Company’s behalf

In order to

  • gain any commercial, contractual or regulatory advantage for the Company in a way which is unethical
  • gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual

2.        Purpose

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company’s business is conducted in a socially responsible manner.

The company’s aim therefore is to limit its exposure to bribery by:

  • Setting out a clear anti-bribery policy
  • Training all employees so that they can recognise and avoid the use of bribery by themselves and others
  • Encouraging employees to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;
  • Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution;
  • Taking firm and vigorous action against any individual(s) involved in bribery.

The company recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Company or of the person or body employing them or whom they represent.

This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:

  • Normal and appropriate hospitality
  • The giving of a ceremonial gift on a festival or at another special time
  • The use of any recognised fast-track process which is available to all on payment of a fee
  • The offer of resources to assist the person or body to make the decision more efficiently provided that they are supplied for that purpose only.

3.        Scope

3.1          This policy applies to

  • All employees working in any role, (whether permanent, fixed-term or temporary). 
  • Any individual working for but not employed directly by Vision Training (North East) Limited such as consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, wherever located (collectively referred to as employees in this policy).
  • Any person who takes up the services of the company

3.2          Definition

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage, e.g.

Offering a bribe

You offer a potential business partner tickets to a major sporting event, but only if they agree to do business with us.  This would be an offence as you are making the offer to gain a commercial and contractual advantage. We may also be found to have committed an offence because the offer has been made to obtain business for the company. It may also be an offence for the potential client to accept your offer.

Receiving a bribe

An employer offers your daughter a job with their company if you pass all the current learners completing their apprenticeship that are employed by that company.

4.        Roles and Responsibilities

4.1          Directors

The directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

4.2          Head of Centre

The Head of Centre 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.

4.3          Management

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.

4.4          Employee Responsibility
The prevention, detection and reporting of bribery is the responsibility of all employees throughout the company. Suitable channels of communication by which employees or others can report confidentially any suspicion of bribery will be maintained via the whistle-blower’s procedure.

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