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ANTI BRIBERY POLICY

 

Responsibility for this policy

The board of directors of PMD Magnetics has responsibility for ensuring this policy complies with their legal and ethical obligations.

 

The board of directors of PMD Magnetics will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness.  Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

 

What is bribery

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.  There are 4 types of offence as set out in the Bribery Act 2012:-

  • Giving a bribe
  • Receiving a bribe
  • Bribing a foreign public official: and
  • A corporate offence of failing to prevent bribery by an associated person for the organisation’s benefit

 

What is not acceptable

When working with or on behalf of PMD Magnetics, it is not acceptable to:

  • Give, promise to give, or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received solely because of that (rather than because of a business reason for providing the advantage such as lower price, better service etc)
  • Give, promise to give, or offer a payment, gift or hospitality to a government official, agent or representative to ‘facilitate’ or expedite a routine procedure
  • Request, agree to receive or accept payment from a 3rd party that you know or suspect is offered with the expectation that it will obtain a business advantage for them
  • Request, agree to receive, or accept a gift or hospitality from a 3rd party if you know or suspect that is is offered or provided with a expectation that a business advantage will provided by PMD Magnetics in return
  • Engage in any activity that might lead to a breach of this policy

 

 

V Finch
March 2018