Anti-Bribery Policy

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.

Employee Responsibilities

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.

Record Keeping

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.