Millward, May & Co - Wokingham Accountants
Wokingham Accountants

Policy

Anti-Bribery

1. INTRODUCTION

Bribery is defined as the offering, giving, receiving, or soliciting of any financial or other advantage to improperly influence the performance of a function or activity. Millward, May & Co Limited ("the Company") is committed to maintaining the highest standards of ethical conduct and integrity in all business dealings and has a zero-tolerance policy towards bribery and corruption.

Bribery is a criminal offence under the Bribery Act 2010. Failure to comply with this Act can result in severe legal and reputational consequences for the Company and its personnel. This policy outlines our commitment to complying with the law and ensuring transparency and integrity in our operations.

2. Scope

This policy applies to:

  • All employees, officers, and directors of Millward, May & Co Limited, irrespective of role or location.

  • Third parties acting on behalf of the Company, including contractors, consultants, agents, and suppliers.

The Company expects all third parties engaged in its operations to adhere to the principles outlined in this policy.

3. PURPOSE

The purpose of this policy is to:

  • Ensure compliance with the Bribery Act 2010 and all relevant anti-bribery laws.

  • Promote transparency, integrity, and ethical business conduct.

  • Prevent and mitigate the risks of bribery and corruption within the Company's operations.

4. DEFINITIONS OF BRIBERY AND CORRUPTION

A Bribe is any inducement or reward that is offered, promised, requested or provided in order to gain a commercial, contractual, regulatory or personal advantage. In most cases, a bribe will be a financial or other advantage given to a person in order for them to perform a relevant function or activity improperly, or to reward them for doing so.

Bribes, in the form of financial or other advantages, may include:

  • money (whether in the form of cash or cash equivalent)

  • gifts

  • hospitality and entertainment

  • loans

  • services

  • preferential treatment

  • discounts

  • promises to provide financial or other advantages in the future

For something to be considered a bribe and be subject to this Policy:

  • the timing of the bribe is irrelevant and any payments made, or advantages given, after a relevant event are considered bribes

  • the payment made, or advantage given, can be given or received unknowingly

  • it is also not necessary for the bribed party to actually receive a benefit as a result of the bribe

Corruption is the misuse of office or power for private gain. Bribery is a form of corruption which means in the course of business giving or receiving money, gifts, meals, entertainment or anything else of value as an inducement to a person to do something which is dishonest or illegal.

5. PROHIBITED CONDUCT

The following acts are criminal offences and strictly prohibited:

  • offer a bribe

  • accept a bribe

  • bribe a foreign official

  • as a commercial organisation, to fail to prevent a bribe

If you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. Millward, May & Co Limited could also face prosecution and be liable to pay a fine.

If you are offered or solicited for a bribe, you must decline unless your immediate safety is at risk. In such cases, report the incident to Emma Cooke, Director as soon as possible and provide a written account of the event.

6. REPORTING OBLIGATIONS

Employees and third parties must report any suspected or actual instances of bribery or corruption to Emma Cooke, Director. Reports will be treated confidentially, and no individual will face retaliation for raising a genuine concern in good faith.

7. GIFTS AND HOSPITALITY

Employees must not offer or accept gifts or hospitality that could influence, or be perceived to influence, business decisions. The following are prohibited:

  • Hospitality that is lavish in nature or a frequent occurrence.

  • Gifts valued above £50.

  • Gifts involving cash or cash equivalents (e.g., vouchers).

  • Hospitality or gifts given or received in secret

  • Hospitality or gifts received in the name of an individual rather than Millward, May & Co Limited

Gifts and hospitality that are proportionate and transparent, with no expectation of return favour, are permissible but must be recorded appropriately.

8. RECORD-KEEPING

The Company requires accurate and transparent record-keeping for all transactions to prevent fraudulent activity. Employees must:

  • Declare and document all gifts and hospitality received or offered.

  • Submit expense claims with clear justifications.

Millward, May & Co Limited takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.

9. CONSEQUENCES OF NON-COMPLIANCE

Millward, May & Co Limited takes compliance with this Policy very seriously and failure to comply with this Policy puts both Staff and the Company at significant risk. The Company will:

  • Conduct thorough investigations of suspected breaches.

  • Impose disciplinary measures, including termination of employment or contractual relationships.

  • Report criminal offences to relevant authorities as required by law.

10. POLICY REVIEW

This policy will be reviewed periodically to ensure compliance with applicable laws and regulations. Millward, May & Co Limited reserves the right to amend this policy without prior notice.