Anti Bribery Policy
1. POLICY STATEMENT
In compliance with the Bribery Act 2010, the Managing Directors (“MD”) and Boards in the Oliver Valves group of companies “Oliver Valves Group”, which comprises of:
- Oliver Hydcovalves Limited,
- Oliver Valves Limited,
- Oliver Twinsafe Valves Limited and
- Oliver Valvetek Limited
Make the following policy statement about the anti-bribery and corruption culture which they expect in Oliver Valves.
1.1 Oliver Valves Group is determined to prevent, deter and detect fraud, bribery and all other corrupt business practices. Oliver Valves will not tolerate corrupt or fraudulent practices contrary to the Bribery Act 2010 and the applicable laws of those countries in which any business of Oliver Valves Group operates.
1.2 This anti-bribery policy (“Policy”) enables the Directors and employees of Oliver Valves Group to understand and participate in action aimed at eliminating bribery and corruption in business.
1.3 It is mandatory that all Directors and those employed by Oliver Valves Group, including workers, temporary agency staff, contractors (“Staff”) and agents, note that it is against this Policy to:
- Give or receive a bribe;
- Promise, offer, request or agree to receive a bribe;
- Bribe a foreign public official;
- Act dishonestly or without integrity at any time and fail to safeguard the Oliver Valves Group resources for which they are responsible;
- Fail to comply with the Bribery Act 2010 and all laws and regulations of any countries in which Oliver Valves Group operates, or hopes to operate, in respect of the lawful and responsible conduct of business.
1.4 For Directors and Staff (or any person purporting to act in such a capacity), consenting to (is aware and agrees) or conniving in (“turns a blind eye to”) the commission of any of the above.
1.5 This Policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate, lawful and are properly recorded:
- Normal, bona fide and appropriate hospitality which seeks to improve the image of Oliver Valves Group, better to present services, or establish cordial relations. For example, hospitality which is commensurate with the reasonable and proportionate such as the provision of dining and tickets to an event will not normally be considered to be a breach of this Policy or the Bribery Act 2010 and associated official guidance;
- The giving or receiving of a token ceremonial gift on a festival or at another special time.
1.6 This Policy prohibits payments (including “facilitating” or “expediting” payments) to others in order to secure prompt or proper performance of routine duties.
2.1 This Policy applies to all businesses within Oliver Valves Group. If the Directors of the firm do not comply with this Policy, the MD and Board of Oliver Valves Group companies will take steps to ensure compliance of the Policy.
2.2 It is responsibility of all Directors and Staff to ensure that this Policy is fully implemented and full compliance with it is achieved.
2.3 The MD and Boards within Oliver Valves companies take responsibility for establishing a culture within Oliver Valves group in which corruption will not be tolerated, and for the effective design and implementation of the firm’s anti-corruption programme.
3. POLICY FRAMEWORK
3.1 Every Oliver Valves Group business is required to have an effective compliance programme that prohibits unethical conduct, which includes but is not limited to, the following components:
- whistleblowing policy for reporting and investigation of allegations of fraud, bribery and other corrupt practices;
- applicable disciplinary procedures for Directors and Staff who are found to have engaged in practices forbidden by this Policy,
- Programme for monitoring the effectiveness of such controls in compliance with the Bribery Act 2010 and other statutory enactments relevant to the Policy.
3.2 Consequently, Oliver Valves Group and each of its businesses must take the appropriate steps to ensure that it and all its Directors and Staff and those acting on its behalf:
- Comply with and meet all legal and regulatory requirements governing the lawful and ethical conduct of business, in whatever jurisdiction concerned;
- Report all breaches or suspected breaches of this Policy;
- Fully investigate all reports and, if appropriate, invoke disciplinary measures;
- Take steps to stop a continued or repeated breach of the Policy;
- Inform, train, and be aware of their personal responsibilities under this Policy;
- Take appropriate steps to make sure that subsidiaries (and third party business Directors i.e. joint ventures, contracting companies) ensure that their staff do not, engage in any conduct contrary to this Policy, particularly if there are factors that might increase the risk of breach of this Policy, such as accepted custom and practice within the country of operation;
- Ensure that all transactions are properly and accurately recorded and hospitality received or given over the value of £250 (in aggregate in any one year) is recorded with the appropriate person in the management structure.
4. RELATED OLIVER VALVES POLICIES AND OTHER DOCUMENTS
4.1 The Oliver Valves Group policies and other documents related to this Policy statement are:
- The Oliver Valves Group Whistleblowing Policy;
- The Bribery Act 2010;
- HM Government’s “Guidance about procedures which relevant commercial organisations can put into place to prevent persons associated with them from bribing (Section 9 of the Bribery Act 2010));
- Other documents which from time to time may be referred to or used by Oliver Valves in relation to anti-bribery work.
5. KEY CONTACTS IN OLIVER VALVES COMPANIES
Policy Owner: The Boards and MDs in Oliver Valves Companies
First Point of Contact for reporting suspected breach:-
- Immediate Manager (if immediate manager is suspected of breach to be informed upon, the immediate manager’s manager);
- Other persons in accordance with the “Whistleblowing Policy” attached;
6. MONITORING AND COMPLIANCE
The Oliver Valves Compliance Committee will review compliance with this Policy by ensuring that the following laws and /or procedures in the suggested documents are adhered to:
- Oliver Valves Group Whistleblowing Policy;
- Bribery Act 2010 and HM “Government’s guidance about procedures which relevant commercial organisations can put into place to prevent persons associated with them from bribing (Section 9 of the Bribery Act 2010)”)
- Other documents which from time to time may be referred to or used by the company in relation to anti-bribery work.
6.2 Compliance will be monitored through:
- inspection of procedures and laws set out in 6.1 above as instructed by the Boards of Oliver’s Valves Group companies;
- annual review of procedures and risk assessments as initiated, controlled and undertaken by the Compliance Committee through persons that they will designate to act on their behalf