Anti-Bribery and the Corruption Policy

20/01/2024

About This Policy

It is our policy to conduct all of our business in an honest and ethical manner. Forward Digital 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.

Any employee who breaches this policy (or the spirit of 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. Where a breach of this policy amounts to an offence under the Bribery Act 2010, the employee concerned may face criminal prosecution.

This policy does not form part of any employee's contract of employment and we may amend it at any time.

Who Must Comply with This Policy?

This policy applies to all persons working for Forward Digital or on our behalf in any capacity, including employees at all levels, directors, trustees, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third party representatives, business partners and any other person associated with Forward Digital.

What Is Bribery?

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 that is intended to influence a decision or action.

Bribery includes offering, promising, giving, accepting, or seeking a bribe.

Corruption means any form of abuse of power for business and/or personal gain and may include, but is not limited to, Bribery.

All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with Reece Charsville.

Specifically, you must not:

• give or offer any payment, gift, hospitality, or other benefit in the expectation or hope 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.
• engage in any other activity that might amount to Bribery or Corruption or otherwise lead to a breach of this policy.
• 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.

Gifts and Hospitality

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.

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 preferential treatment (for example, during contractual negotiations or a tender process).

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.

Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers, and business partners.

For rules relating to the giving and/or receiving of gifts to and/or from the young people that Young Bristol works with, please refer to our Conduct and Standards Policy.

Training

Anti-Bribery training will be provided to specific key members of staff and reviewed annually to ensure they are up to date with the appropriate legislation.

How To Raise A Concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with your Line Manager. If you feel you cannot raise it with any of the above, then please discuss with the Director.

Record-Keeping

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.

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.

Monitoring and Review

Forward Digital will establish and put in place appropriate performance measures and reporting systems to monitor performance against metrics and compliance with the relevant policies, procedures, and controls.

Forward Digital will continue to review our policy annually and update as we see fit and in accordance with nay updates to U.K. government legislation.

Name and Title: Harry Bendix-Lewis - Director.