Bribery & Corruption Policy

Within the UK, the Bribery Act 2011 makes bribery and corruption illegal; it also holds UK companies liable for failing to implement adequate procedures to prevent such acts. It is therefore a continuing fundamental principle of Halspan to conduct all of its business in an open, honest, and ethical manner. Halspan maintains a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships, within all jurisdictions in which we operate.

The purpose of this policy is to further

Mitigate the risk of bribery relevance to business conduct and applies to individuals working at all levels inclusive of, Employees (whether permanent, fixed term, or temporary), Managers, Directors, in addition to Business Advisers and Contractors or any other person working for or performing a service on behalf of Halspan.
Set out our responsibilities and of those working for us, in observing and upholding our position on bribery, and corruption.
Provide information, and guidance to those working for Halspan in whatever capacity on how to recognise, and deal with bribery, and corruption issues.

Any Employee who is aware of possible bribery and corruption activities should feel comfortable in disclosing such details, and a commitment has been made within Halspan to ensure that employees who do come forward with such information are protected, to the fullest extent possible.

The effectiveness of this policy will be subject of monitoring and review at least annually, for its ongoing suitability, adequacy, and effectiveness by the Directors of Halspan. Any improvements identified will be made as soon as possible and communicated to all concerned parties.

What is Bribery

A bribe is an inducement or reward offered, promised, or provided in order to gain any commercial, contractual, regulatory or personal advantage. Examples of such are:

Offering a Bribe; You offer a potential Customer, 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. Halspan may also be found to have committed an offence, because the offer has been made to obtain business for us. It may also be an offence for the potential Client to accept your offer.
Receiving a Bribe; A Supplier gives one of your family members a job but makes it clear that in return they expect you to use your influence within Halspan, to ensure the continuity of business with them. It is an offence for a Supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.

Gifts and Hospitality

Halspan bribery and corruption policy is not designed to prohibit the acceptance or offer of reasonable and customary gifts, and hospitality. The giving or receipt of gifts is permissible, on condition that the following requirements are maintained:

It is not made with intention of influencing a third party, to obtain or retain business or a business advantage, or to reward for the same and it complies with national and local law.
It is given in our name, not in the name of Halspan.
It does not include cash or a form of cash equivalent i.e., gift vouchers, and is appropriate in the circumstances.
Taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time; and
It is given openly, not secretly.

The test always to be applied, is whether in all the circumstances the gift or hospitality, is reasonable and justifiable, whilst the intention behind the gift should always likewise, be considered.

Facilitation Payments

Halspan does not make, and will not accept, facilitation payments (widely known as ‘kickbacks’) of any kind, such payments are usually in the form of payments that are typically small, unofficial, and made to secure or expedite a routine action.

Therefore, if you are requested to make a payment on behalf of the Company, you should always be mindful of the reason for the payment, and whether the amount requested is proportionate to the goods or services provided or proposed to be provided.

If any form of payment is made, you must always ask for a receipt detailing the reason for the payment. Likewise, if for any reason you have suspicions, concerns or queries regarding a payment, you are required to raise these with your immediate Manager or a Director.

Responsibilities of Individuals

Each applicable person must ensure that you 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 Halspan, under its control or acting on its behalf. The same persons are required to avoid any activity that might lead to or suggest a breach of this policy.

Employees must promptly notify their immediate Manager or Director, if they believe or suspect that a conflict with this policy has occurred or may occur in the future.

Record-keeping

Financial records and appropriate internal controls will be maintained by the Company, in order to provide evidence for the business reason in making payments to third parties.

Each affected individual must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to review by the Company. They must also ensure all claims relating to hospitality, gifts or expenses incurred to third parties are record along with the reason for expenditure.

All accounts, invoices, other documents, and records relating to dealings with third parties, such as clients, suppliers and business contacts should be prepared, and maintained with strict accuracy, and completeness. No details of accounts must be withheld, in order to facilitate or conceal improper payments.

Raising a Concern

Any suspicions or concerns of malpractice must to be brought to the immediate attention of the Managing Director, or at the earliest possible stage. Likewise, if you are unsure whether an instance constitutes bribery or corruption, or have any other form of queries, these should be raised with your immediate Manager, or a Director.

Victim of Bribery or Corruption

It is important that if you consider that you are a victim of bribery or corruption inform your immediate Manager, or a Director. Likewise, if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of any other another form of unlawful activity.

Individuals Protection

Halspan aim is to encourage openness and we will support anyone who raises genuine concerns and in good faith under this policy, even if they turn out to be mistaken. In addition to ensuring that no person suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion, that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should inform your immediate Manager or Director immediately. If the matter is not remedied and you are an employee, you should request for the matter to be raised formally using the Company Grievance Procedure.

Awareness and Communication

Awareness and communication of this policy will be made to new employees of Halspan during the induction process for all new employees (whether permanent, fixed term, or temporary).

Existing employees (whether permanent, fixed term, or temporary) will be made aware by their immediate Manager, or Director as applicable, on how to implement and adhere to this policy.

Halspan approach to bribery and corruption will be communicated to all consultants, other business advisers, and contractors or any other person working for, or performing a service on behalf of Halspan, as deemed relevant to do so, at the outset of our business relationship with them and as appropriate thereafter.