FMG takes a zero tolerance approach towards all forms of bribery and corruption. This policy aims to ensure that FMG complies with the Bribery Act 2010 and all applicable laws, statutes and codes relating to anti-bribery and anti-corruption and that business is conducted in an honest and ethical manner.
FMG is committed to acting professionally, fairly, and with integrity in all business dealings and relationships and implementing and enforcing effective systems to counter bribery and corruption.
This policy sets out FMG’s responsibilities, and of those working for FMG, in observing and upholding our legal compliance and position on bribery and corruption. It also provides information and guidance to those working for FMG on how to recognise and deal with bribery and corruption issues.
Bribery and corruption is punishable for individuals by unlimited fines and up to ten years’ imprisonment and if FMG are found to have taken part in corruption, could face an unlimited fine, be excluded from tendering for commercial contracts and face reputational damage.
What is bribery and corruption?
A bribe is an inducement or reward (financial or otherwise) offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
Corruption is “the abuse of entrusted power for private gain”.
Who is covered by the policy?
This policy applies to all individuals working at all levels and roles including senior managers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, seconded employees, homeworkers, agency employees, agents, or any other person associated with or representing FMG.
All persons to whom this policy applies must not engage in any form of bribery or corruption anywhere in the world, and must not request that any third party does so on their behalf.
Working with customers, suppliers and third parties
FMG only wish to work with those customers, suppliers and third parties who are committed to acting to the standards contained in this policy. Where customer, suppliers or third parties are providing goods or services through FMG’s contract, they will be subject to terms requiring compliance to anti-bribery and anti-corruption legislation and policies.
Gifts and Hospitality
Corporate hospitality, gifts and promotional, or other business expenditure which seeks to improve the image of FMG, better present our products and services or establish relations, is recognised as an established and important part of doing business. Hospitality and gifts can however amount to a bribe. FMG’s gifts and entertainment policy and expenses policy must be complied with at all times. Please click on the links below to view these policies.
Charitable and political donations and sponsorship
From time to time, FMG may make charitable donations either of its own volition or in response to requests from third parties. Care must be taken when making any charitable donation on the behalf of FMG to ensure that such a donation is for bona fide charitable purposes and is not in reality a bribe (or likely to be considered to be a bribe by an independent observer). Accordingly, all charitable donations to be made by FMG must be pre-authorised by the Board.
As a matter of policy, FMG does not make donations to political parties.
Employees must ensure that they 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 FMG and under FMG’s control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Employees must notify line management as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers something to gain a business advantage with FMG, or indicates that a gift or payment is required to secure their business.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. FMG reserves the right to terminate any contractual relationship with other workers, if this policy is breached.
A register of all hospitality or gifts accepted or offered by employees, will be kept by the HR department and all employees who offer or accept gifts or hospitality must report these to the HR department so that this register can be maintained. All gifts or hospitality accepted or offered will be in accordance with FMG’s gifts and entertainment policy.
Expense claims relating to hospitality, gifts or expenses incurred to third parties must be submitted in accordance with FMG’s expenses policy and specifically record the reason for the expenditure. All expenses claimed will be in accordance with FMG’s expenses policy.
Declaration of Interest
All individuals, including senior managers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, seconded employees, homeworkers, agency employees, agents, or any other person associated with or representing FMG, must declare any personal or business interests that they or a close relative has in relation to any current or future business transaction involving FMG to the HR department, who will record this information in a central register.
How to raise a concern
Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. Any doubt whether a particular act constitutes bribery or corruption, or if any other queries, should be raised with the HR Department. Concerns should be reported by following the procedure set out in FMG’s whistleblowing policy. Please click on this link to view the whistleblowing policy.
FMG are 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.
FMG will regularly communicate our anti-bribery and corruption measures to employees and associated persons. Training sessions where appropriate will be set up by the Human Resources department.
The HR department will monitor the adherence and review the implementation of this policy regularly.