1. Policy Statement
We are wholeheartedly dedicated to running this lead generation website transparently, ethically, and within the bounds of the law. We maintain a zero-tolerance policy against bribery or corruption and pledge to carry out our duties with professionalism, equity, and unwavering integrity.
It is our firm pledge to adhere to all relevant laws governing the prevention of bribery and corruption in every jurisdiction in which we operate, with a special focus on the Bribery Act of 2010 in the UK.
Failure to comply with anti-bribery or corruption legislation may result in prosecution, with potential consequences including imprisonment for individuals for up to 10 years and significant financial penalties. Hence, we approach our legal obligations with the highest sincerity.
The objective of this Policy is to communicate our stance on corruption and bribery to external parties. Our employees are encouraged to consult our internal guidelines for further clarification.
In the context of this policy, third parties encompass individuals or entities engaging with us, including current and prospective clients, suppliers, business associates, regulatory bodies, and governmental organisations, among others.
2. Who Does The Policy Cover?
- Every person associated with our organisation, regardless of their role, includes partners, executives, managers, staff members, contractors, interns, temporary workers, volunteers, and representatives.
- Additionally, third parties contracted by our organisation are required to adhere to the outlined principles in this policy, subject to thorough due diligence.
3. What Are Bribery And Corruption?
Corruption is the exploitation of a position or authority for one’s own benefit. Bribery involves the offering, pledging, or provision of any benefit to influence the decisions or actions of another party unduly.
4. SRA’s Position On Bribery
We operate under the authorisation of the SRA Code of Conduct, which sets forth the standards and obligations that the firm must uphold for the benefit of our clients and the public interest.
In addition to complying with the Bribery Act of 2010, we must follow the legal rules set in the SRA code of conduct.
5. Our Standards
We unequivocally forbid anyone associated with our organisation from:
- Offering, pledging, or providing any benefit, be it monetary, gifts, or entertainment, with the expectation or suggestion that a business favour will be reciprocated.
- Offering incentives to government officials to accelerate or “facilitate” routine duties.
- Receiving any sort of benefit from a third party if there’s reason to believe that such a deal suggests a desire for reciprocal financial favour.
- Taking amenities or presents from a third party in the expectation of receiving a benefit from the company in exchange.
- Retaliation towards any employee who declines to participate in bribery or discloses a potential violation of this rule.
- Being involved in any conduct that may constitute a violation of this agreement.
6. Facilitation Payments And Kickbacks
Facilitation payments are usually unimportant and unrecorded contributions meant to expedite government processes, whereas kickbacks are normally payments paid to obtain an organisation’s benefit. Both practices are explicitly prohibited.
7. Donations
We refrain from making political donations. Charitable contributions are only given when they are lawful and ethical according to local legislation.
8. How To Raise A Concern
We urge third parties to promptly report any instances of malpractice or suspicions they may have. Please direct any concerns to Armen Andonian and send an email to info@sponsorlicenselawyers.co.uk
9. Monitoring And Assessment
We must regularly track and evaluate this policy’s efficiency, as well as conduct regular evaluations regarding its suitability and sufficiency.
