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1. Introduction
The Bribery Act which has recently been enacted represents the
biggest
change in UK laws in this area of business for many generations. There
are a new set of risks to navigate with the introduction of the
legislation.
The Act introduces a new crime of “failure to prevent” bribery,
which means that companies who are unable to demonstrate that
they have implemented “adequate procedures” to prevent corrupt
practices within their ranks, or by third parties on their
behalf, could be exposed to unlimited fines as well as other
collateral consequences such as loss of business, or business
failure.
Rocket Medical plc. values its reputation for ethical behaviour
and for financial probity.
It recognises that over and above the commission of any crime,
any involvement
in bribery will also reflect adversely on its image and
reputation.
The purpose of this Policy Statement is to set out for Board
members and employees of Rocket Medical PLC the aim of limiting
Rocket Medical plc’s exposure to bribery by:
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Setting out a clear anti-bribery policy:
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Conducting a risk analysis of the organisation.
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Training all at-risk employees and Board members so that
they can recognise and avoid the use of bribery by
themselves and others.
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Encouraging its employees to be vigilant and to report any
suspicions of bribery, providing them with suitable channels
of communication and ensuring sensitive information is
treated appropriately.
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Rigorously investigating instances of alleged bribery and
assisting police and other appropriate authorities in any
resultant prosecution.
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Taking firm and vigorous action against any individual(s)
involved in bribery.
2. Scope:
This Policy Statement applies to Board Members, and all
employees who work for the Rocket Medical plc.
Rocket Medical PLC
prohibits the offering, the giving,
the solicitation or the acceptance of any bribe, whether cash or
other inducement.
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In order to gain
any commercial, contractual or regulatory advantage for the
Rocket Medical PLC in a way which is unethical
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In order to gain
any personal advantage, pecuniary or otherwise, for the
individual or anyone connected with the individual.
3. Further Clarification:
Rocket Medical plc recognises that
market practice varies across the areas in which it does
business and what is normal and acceptable in one place may not
be in another.
This policy statement prohibits any
inducement which results in a personal gain or advantage to the
recipient or any person or body associated with them, and which
is intended to influence them to take action which may not be
solely in the interests of Rocket Medical plc or of the person
or body employing them or whom they represent.
This policy is not meant to prohibit
the following practices providing they are customary in a
particular market, are proportionate and are properly recorded:
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Normal and appropriate hospitality.
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The giving of a ceremonial gift on
a festival or another special time.
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The use of any recognized
fast-track process which is available to all on payment of a
fee.
Further guidance is contained in the Rocket
Medical plc’s Whistle-blowing procedure and Rocket
Medical plc's Gifts and Corporate Hospitality
policy.
Inevitably, decisions as to what is
acceptable may not always be easy. If anyone is in doubt as to
whether a potential act constitutes bribery, the matter should
be referred to your manager and if necessary, guidance should
also be sought from the Managing Director.
4. Employee and Board Responsibility
The prevention, detection and reporting
of bribery is the responsibility of all employees and Board
Members throughout the Rocket Medical PLC. Suitable channels of
communication by which employees and others can report
confidentially any suspicion of bribery will be maintained by
the Whistle-blowing procedure.
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