Anti-bribery and corruption compliance
1) Policy Statement
TW Writing & Consulting Ltd has a zero-tolerance approach to bribery and corruption. We comply with the UK Bribery Act 2010 and require all employees and third parties acting on our behalf to do the same. We will take disciplinary and contractual action where this policy is breached.
2) Scope And Definitions
This policy applies to all employees, officers, contractors, agency workers, intermediaries, suppliers and any other “associated persons”. A bribe is any financial or other advantage offered, given, requested or received to induce or reward improper performance.
3) Prohibited Conduct
- Offering, giving, requesting or accepting bribes
- Making facilitation payments
- Improperly influencing public officials
- Authorising, assisting or ignoring bribery by third parties
4) Gifts, Hospitality And Expenses
- Reasonable hospitality is permitted where proportionate and transparent.
- No gifts or equivalent (e.g., vouchers) allowed.
5) Charitable And Political Contributions
- Charitable donations require approval and must be recorded.
- No political donations unless approved by the board/owners and recorded.
6) Third Parties And Due Diligence
- Conduct proportionate due diligence for higher-risk third parties (e.g., commission-based agents).
- Contracts with third parties must include anti-bribery clauses, audit rights and termination for breach.
7) Conflicts Of Interest
- Declare any actual or potential conflicts.
8) Reporting And Whistleblowing
- Report concerns to director.
- No retaliation against anyone who raises a concern in good faith.
10) Monitoring And Review
- The director will review this policy annually or sooner if risks change.
11) Breach And Consequences
- Disciplinary action up to summary dismissal for employees.
- Termination of contracts and possible reporting to authorities for third parties.
12) Roles And Contacts
- Policy owner: TW Writing & Consulting Ltd
- Compliance contact: Tom Wicker