Anti-Bribery and Corruption Policy
- What does this policy cover?
1.1 The purpose of this Anti-Bribery and Corruption Policy is to define the responsibilities of Soundman and its employees regarding our zero-tolerance stance on bribery and corruption. We aim to uphold ethical standards and prevent bribery.
1.2 Additionally, this policy serves as a source of information and guidance for all Soundman employees, helping them identify and address bribery and corruption issues while understanding their individual responsibilities.
- Policy statement
2.1 Soundman is firmly committed to conducting business in an ethical and honest manner. We have implemented robust systems to prevent bribery and corruption. Our zero-tolerance approach extends to all our business dealings and relationships, regardless of the location.
2.2 We are fully compliant with all anti-bribery and corruption laws in the jurisdictions where we operate, including the Bribery Act 2010, in the UK.
2.3 Recognizing the serious consequences of bribery and corruption, such as imprisonment and reputation damage, we are dedicated to preventing such activities and fulfilling our legal obligations.
3. Who is covered by the policy?
3.1 This anti-bribery policy applies to all individuals associated with Soundman, including employees (temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or organization working with us. This includes all our subsidiaries and their employees, regardless of their location.
3.2 The policy also extends to Officers, Trustees, Board, and Committee members at all levels.
3.3 In the context of this policy, “third-party” refers to any individual or organization with whom Soundman conducts business. This includes clients, customers, suppliers, distributors, business contacts, agents, advisers, and government/public bodies, along with their representatives and officials, politicians, and public parties.
3.4 Any arrangements with third parties must include clear contractual terms that mandate compliance with anti-bribery and corruption standards and procedures.
- Definition of bribery
4.1 Bribery involves offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or advantage to influence an action or decision.
4.2 A bribe includes any inducement, reward, or valuable item offered to obtain a commercial, contractual, regulatory, or personal advantage.
4.3 It is essential to note that bribery encompasses not only offering a bribe but also accepting one, which is equally unlawful.
4.4 Bribery is strictly prohibited at Soundman. If unsure about whether an action constitutes bribery or a genuine gift, employees must seek advice from the company’s compliance manager.
a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.
- What is and what is NOT acceptable
5.1 This section covers 4 areas:
- Gifts and hospitality.
- Facilitation payments.
- Political contributions.
- Charitable contributions.
5.2 Gifts and hospitality
Soundman accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:
- It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
- It is not made with the suggestion that a return favour is expected.
- It is in compliance with local law.
- It is given in the name of the company, not in an individual’s name.
- It does not include cash or a cash equivalent (g. a voucher or gift certificate).
- It is appropriate for the circumstances (g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
- It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
- It is given/received openly, not secretly.
- It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
- It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).
- It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.
5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.
5.4 Soundman recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.
5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.
5.6 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.
5.7 Facilitation Payments and Kickbacks
Soundman does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery.
that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
5.8 Soundman does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.
5.9 Soundman recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:
- Keep any amount to the minimum.
- Ask for a receipt, detailing the amount and reason for the payment.
- Create a record concerning the payment.
- Report this incident to your line manager.
5.10 Political Contributions
Soundman will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.
5.11 Charitable Contributions
Soundman accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.
5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.
- Employee Responsibilities
6.1 As an employee of Soundman you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.
6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.
6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.
6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Soundman has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
- What happens if I need to raise a concern?
7.1 This section of the policy covers 3 areas:
- How to raise a concern.
- What to do if you are a victim of bribery or corruption.
7.2 How to raise a concern
If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Soundman, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal.
7.3 Soundman will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.
7.4 What to do if you are a victim of bribery or corruption
You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.
If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Soundman understands that you may feel worried about potential repercussions. Soundman will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.
7.6 Soundman will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.
7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.
7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately.
- Training and communication
8.1 Soundman will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.
8.2 Soundman’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.
8.3 Soundman will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities.
- Record keeping
9.1 Soundman will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.
- Monitoring and reviewing
10.1 Soundman’s compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.
10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.
10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.
10.4 This policy does not form part of an employee’s contract of employment and Soundman may amend it at any time so to improve its effectiveness at combatting bribery and corruption.