1. Scope and law
This policy applies to directors, employees, contractors, agents and other persons performing services for or on behalf of the company. It reflects the Bribery Act 2010, including offences relating to giving or receiving bribes, bribery of foreign public officials and failure by a commercial organisation to prevent bribery.
2. Prohibited conduct
- offering, promising, giving, requesting or accepting an improper financial or other advantage
- using an intermediary to do something that the company would not do directly
- making facilitation payments, regardless of local custom
- providing gifts, hospitality, employment or other benefits to influence a decision improperly
- concealing an inducement through a false invoice, expense, rebate, donation or sponsorship
3. Gifts and hospitality
Reasonable and proportionate hospitality may be acceptable where it has a genuine business purpose, is permitted by the recipient’s rules, is not cash or a cash equivalent and cannot reasonably be seen as intended to influence a decision. Anything unusual, repeated, high value or involving a public official requires prior director approval and a written record.
4. Third parties
Risk-based due diligence is carried out before appointing agents, introducers, consultants and material suppliers. Contracts may require compliance warranties, audit information and termination rights. Payment must reflect genuine work, be supported by an accurate invoice and be made to a verified account in the contracting party’s name.
5. Conflicts of interest
Actual or potential conflicts, including close personal relationships, outside interests or financial interests connected with a business decision, must be declared promptly. A director will decide how the conflict is managed and record the decision.
6. Political and charitable activity
The company does not make political contributions to secure business advantage. Charitable donations and sponsorship must be legitimate, proportionate, approved and recorded. Personal political activity must not be represented as the company’s position.
7. Reporting
Concerns should be reported without delay to a director or to info@motionworkforcesolutions.com. Reports made honestly will be considered sensitively and retaliation is prohibited. Where immediate action is required, a person should decline or pause the transaction where safe to do so.
8. Records and consequences
Books, invoices, expenses and approvals must accurately describe the transaction. Breach may result in disciplinary or contractual action, termination of a relationship and referral to law enforcement. The company reviews its controls in proportion to the bribery risks it faces.