Anti-Bribery Policy


Scope and Purpose

Bytes is dedicated to ensuring full compliance with all anti-bribery and corruption laws and regulations and actively encourages employees, Contractors, Agency staff, Customers, Partners or any person working with or on behalf of the company, to report bribery or suspected bribery to a member of the Bytes UK Board Immediately. All reports will be dealt with in a safe and confidential manner.

The purpose of the Bribery Policy is to ensure that, all who perform services for OR on behalf of Bytes are aware of what is and what is not acceptable from a gift or entertainment perspective and what is within the limits of the Law.

Definition of Bribery

Bribing (Active) – To offer, promise or give someone an advantage in connection with the improper performance of a relevant function.

Being Bribed (Passive) – To request, accept or agree to receive advantage in connection with the improper performance of a relevant function.

How this Relates to Bytes

The act of Bribing another person and / or Company is strictly prohibited and includes enticement to sign or agree business on provision of a bribe – financial or otherwise. Likewise accepting an act of Bribery from another person and / or Company is also strictly prohibited.

Last Updated: March 2012

The 6 main principles of this policy are:

  • Risk Assessment – Assessing and reviewing the Bribery risks the Company, persons employed and associated with the Company may be faced with. This process will be periodic, informed and documented.
  • Top Level Commitment – The board and management team enforce a culture to prevent bribery by persons employed or associated with the Company. Bribery is never acceptable. ? Due Diligence – The Company undertakes due diligence procedures to take a proportionate and risk based approach to those it shall engage with to perform services on behalf of the company in order to reduce identified bribery risks. ( see also Corporate Governance)
  • Proportionality – Ensuring procedures to prevent bribery by persons employed and associated with the Company will be proportionate to the bribery risks it faces, and to the nature and scale and complexity of the commercial activities. They will be clear, practical, accessible, effectively implemented and enforced.
  • Communication (including Training) – The company will seek to ensure that its bribery prevention policies & procedures are known and understood throughout the organisation, through internal and external communication, including training proportionate to the risks it faces.
  • Monitoring and Review – The Company will monitor and review procedures designed to prevent bribery by persons employed and associated with it and will make improvements where necessary.

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