About Anti-bribery and anti-corruption policy

The purpose of this policy is to set out Canongate’s commitment to preventing bribery and corruption in all areas of our business. It provides clear guidance on the standards of behaviour expected from employees and anyone acting on our behalf, and explains how to recognise, avoid and report any suspected bribery or corrupt activity. This policy is intended to protect Canongate, our staff and associated persons by ensuring that all business is conducted honestly, fairly, transparently and in compliance with applicable anti-bribery and anti-corruption laws.

The policy applies to all employees, freelancers, directors, agents, contractors and suppliers we work with and anyone acting on our behalf.

The policy is in alignment with the UK Bribery Act 2010 and covers offences such as offering and receiving a bribe both in the UK and across the world and failing to prevent bribery by anyone associated with us.

It is prohibited for any employee or person working on our behalf to offer, give, request or accept any bribe, whether directly or indirectly.

A bribe is any gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or organisation made in order to gain commercial, contractual or regulatory advantage for Canongate, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is improper. This includes facilitation payments or gifts made to speed up routine activities or procedures. If you are offered a bribe, refuse it and report it as set out below.

If we suspect that you have committed an act of bribery or attempted bribery, an investigation will be carried out and, in line with our disciplinary procedure where appropriate, action may be taken against you which may result in your dismissal, or the cessation of our business arrangement with you.

If you, as an employee or person working on our behalf, suspect that an act of bribery or attempted bribery has taken place, even if you are not personally involved, you are expected to report this to your line manager or an Executive Director. You may be asked to give a written account of events.

We realise that the giving and receiving of gifts and hospitality as a reflection of friendship or appreciation where nothing is expected in return may occur, or even be commonplace, in our industry. This does not constitute bribery where it is proportionate and recorded properly.

No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from their line manager or an Executive Director.

Similarly, no gift or offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from their line manager or an Executive Director.

No gift or offer of hospitality will be given to any political party, any politician or any public official. Any donation made to another body should never be to gain an improper advantage, whether this is commercial, political or charitable.

If in any doubt, please refer your query to the Head of HR. Anyone raising a concern in good faith will not suffer any negative actions for raising an issue.

A record is to be made by the relevant line manager of every instance in which gifts or hospitality are given or received. Records should include date, nature and value of gift (or approximate value if it can not be identified exactly), giver, recipient and justification.

If you have any personal, family or business interest that could influence, or appear to influence, a business decision relating to Canongate, you must declare it to your line manager or the Head of HR as soon as you become aware of it. This applies to all business decisions, including those arising from internal and external meetings. Declarations will be recorded and you may be required to remove yourself from the decision-making process.

This policy is regularly reviewed and may be updated at any time. It is approved by Canongate’s Board of Directors.