Anti bribery

Introduction

Codehouse Limited is committed to implementing and enforcing effective systems to counter bribery. Therefore it is the company's policy to conduct all aspects of its business in an honest and ethical manner at all times. This policy applies to all individuals working for Codehouse Limited, including any third parties providing services to the company.

Policy aim

The aim of this policy is to help Codehouse Limited act in accordance with the Bribery Act 2010, maintain the highest possible standards of business practice and advise individuals of the company's 'zero-tolerance' to bribery.

The law

Under UK law (UK Bribery Act 2010), bribery and corruption is punishable for individuals by up to ten years imprisonment. If the company is found to have taken part in corruption or lacks adequate procedures to prevent bribery, it could face an unlimited fine and be excluded from tendering for Government contracts.

Policy statement

Codehouse Limited will not:

Make contributions of any kind with the purpose of gaining any commercial advantage.
Provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a public official in the performance of their duties.
Make, or accept, 'kick-backs' of any kind.

Codehouse Limited will:

Keep appropriate internal records that will evidence the business reason for making any payments to third parties.
Encourage employees to raise concerns about any issue or suspicion of malpractice at the earliest possible stage.
See that anyone raising a concern about bribery will not suffer any detriment as a result, even if they turn out to be mistaken.

Definitions

Bribe is a financial or other advantage offered or given to anyone to persuade them to or reward them for performing their duties improperly or; with the intention of influencing them in the performance of their duties.
Hospitality is the practice of being hospitable. This includes the reception and entertainment of guests/visitors. This policy does not prohibit giving and receiving promotional gifts of low value or normal and appropriate hospitality.
"Kick-backs" or facilitation payments are typically small payments made in return for a business favour or advantage.

Employee responsibility

It is the responsibility of all employees to prevent and report conduct which has taken place which is suspect as a bribe (or corrupt). Any such incidents can be reported to a manager or by using the procedure set out in the company's whistle blowing policy.

Non-compliance

Staff: Failing to observe company policy may lead to disciplinary action in accordance with the company’s disciplinary policy.
Visitors: In the event of a breach of the policy by other organisations, or individuals, Codehouse Limited will take appropriate action.

Monitoring policy

The policy will be monitored on an on-going basis to ensure that it addresses issues effectively. The following will be monitored:

That all individuals working for the company are advised of the policy.
Assessment of any reported incident or related occurrence.

Monitoring of the policy is essential to assess how effective the company has been to establish control of its obligations.

Reviewing policy

This policy will be reviewed and, if necessary, revised in the light of legislative or organisational changes. Improvements will be made by learning from experience and the use of an established annual review.

Policy amendments

Should any amendments, revisions, or updates be made to this policy it is the responsibility of Codehouse Limited's senior management to see that all relevant employees receive notice. Written notice and/or training should be considered.

Policy implementation notice

This is the policy statement of Codehouse Limited.
The overall and final responsibility for this policy is that of the company directors.
Day-to-day responsibility for ensuring this policy is put into practice is delegated to Codehouse Limited.

Policy review date:1st December 2023.