SimpleHelp Anti-Bribery and Corruption Policy
The purpose of this policy is to ensure compliance with the Bribery Act 2010 and other applicable anti-bribery and corruption regulations, and to ensure that SimpleHelp's business is conducted in a socially responsible manner.
Policy Statement
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.
It is SimpleHelp's policy to conduct all of our business in an honest and ethical manner. SimpleHelp takes a zero- tolerance approach to bribery and corruption. SimpleHelp is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever it operates and implementing and enforcing effective systems to counter bribery.
SimpleHelp will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it operates. SimpleHelp is bound by the laws of the United Kingdom, including the Bribery Act 2010, in respect its conduct both at home and abroad.
It is SimpleHelp's policy to conduct all of our business in an honest and ethical manner. SimpleHelp takes a zero- tolerance approach to bribery and corruption. SimpleHelp is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever it operates and implementing and enforcing effective systems to counter bribery.
SimpleHelp will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it operates. SimpleHelp is bound by the laws of the United Kingdom, including the Bribery Act 2010, in respect its conduct both at home and abroad.
Who this Policy Applies To
In this policy, third party refers any individual or organisation that comes into contact with SimpleHelp during the course of SimpleHelp's work. It includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy).
This policy covers:
Bribes
SimpleHelp employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor).
Gifts and Hospitality
SimpleHelp employees must not offer or give any gift or hospitality which could be regarded as illegal or improper, or which violates the recipient’s policies, unless approved in writing by a SimpleHelp director. Employees may not accept any gift or hospitality including:
Political Contributions
We do not make donations, whether in cash or kind, in support of any political parties or candidates.
Charitable Contributions
Charitable support and donations are acceptable (and indeed are encouraged), whether of in- kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. SimpleHelp only makes charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of a SimpleHelp director. All charitable contributions should be publicly disclosed.
This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy).
This policy covers:
- Bribes
- Gifts and hospitality, including payments
- Political contributions
- Charitable contributions
Bribes
SimpleHelp employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor).
Gifts and Hospitality
SimpleHelp employees must not offer or give any gift or hospitality which could be regarded as illegal or improper, or which violates the recipient’s policies, unless approved in writing by a SimpleHelp director. Employees may not accept any gift or hospitality including:
- any cash, or
- any gift with the suggestions of a return favour, directly or indirectly
- unless it is approved in writing by a SimpleHelp director.
Political Contributions
We do not make donations, whether in cash or kind, in support of any political parties or candidates.
Charitable Contributions
Charitable support and donations are acceptable (and indeed are encouraged), whether of in- kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. SimpleHelp only makes charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of a SimpleHelp director. All charitable contributions should be publicly disclosed.
Employee Responsibilities
Employees must ensure that they have 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 SimpleHelp. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify the managing director as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. SimpleHelp reserves its right to terminate our contractual relationship with other workers if they breach this policy.
You must notify the managing director as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. SimpleHelp reserves its right to terminate our contractual relationship with other workers if they breach this policy.
Record Keeping
SimpleHelp keeps financial records and has appropriate controls in place which will evidence the business reason for making payments to third parties. SimpleHelp declares and keeps a written record of all hospitality or gifts accepted. All expense claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with SimpleHelp's expenses policy and specifically records the reason for the 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 accounts are to be kept hidden to facilitate or conceal improper payments.
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 accounts are to be kept hidden to facilitate or conceal improper payments.
Raising a Concern
Employees and customers of SimpleHelp 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 a SimpleHelp director.
Protection
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. SimpleHelp to encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
SimpleHelp is committed to ensuring no one 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 the managing director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the company’s Grievance Procedure.
SimpleHelp is committed to ensuring no one 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 the managing director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the company’s Grievance Procedure.
Communicating this Policy
Training on this policy forms part of the induction process for all new employees. All existing employees will receive regular, relevant training on how to implement and adhere to this policy. In addition, all employees will be asked to formally accept conformance to this policy on an annual basis.
SimpleHelp's zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
SimpleHelp's zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
More Information on this Policy
The SimpleHelp directors have overall responsibility for ensuring this policy complies with SimpleHelp's legal and ethical obligations, and that all those under our control comply with it. 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.
Should you have any concerns related to this policy, or wish to receive more information, please contact us immediately.
Should you have any concerns related to this policy, or wish to receive more information, please contact us immediately.