The general principles of the policy are outlined below:

• • Workers are required to comply with all laws governing Certsure’s operations and shall conduct business in accordance with the highest ethical standards. Workers are expected to maintain consistently high standards of conduct at all times.
  • Workers dealing with contractors, consultants, suppliers, customers and other persons doing business with Certsure shall conduct such activities in the best interests of Certsure without favour or preference.
  • Certsure prohibits the offering, the giving, the solicitation or the acceptance of any bribe whether cash or other inducement to or from any person or company wherever they are situated.
  • Certsure takes a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, and in implementing and enforcing effective systems to counter bribery. We will uphold all laws relevant to ethical issues, particularly those countering bribery and corruption in the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.
  • This policy sets out our responsibilities, and the responsibilities of those working for us, in observing and upholding our position on bribery and corruption. Further, this policy provides information and guidance on how to recognise and deal with ethical, bribery and corruption issues.

In this policy, “third party” means any individual or organisation you come into contact with during the course of your work under the terms of your employment contract. This could include actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

1. Who is covered by the Policy?

2. Conflict of Interest

A conflict of interest could arise when workers are or become involved in an outside business interest which:

• • competes with the activities of Certsure.
  • is a supplier of goods or services to Certsure.
  • interferes with the worker’s obligation to devote their contractual working hours, the requirements of their role and responsibilities, or any other contractual obligations.operates in such a manner as to reflect adversely upon Certsure.
  • have a relationship or association outside of the working environment with a colleague, contractor, client, third parties, customer or supplier, and workers must not allow that relationship or association to influence their conduct or integrity while at work. They must ensure that any such relationships or associations do not have an adverse effect on their work, give rise to a conflict of interest of any kind, or provide any workplace or personal advantage.

Workers are expected to:

• • Declare any commercial and other interests which may influence the way they carry out their duties for Certsure.
  • Declare any prior and/or present association with a client or customer business, the assessment or certification of which they are to be assigned.
  • Devote the whole of their time, attention and abilities during their hours of work to their duties. They may not, under any circumstances, whether directly or indirectly, undertake any other duties of whatever kind during their hours of work for Certsure.
  • Not, without the prior written approval, be engaged or concerned in any business, employment, consultancy or similar relating to Certsure’s industry, or advise any business or individual engaged in the industry outside of normal working hours and shall ensure that any such approved activities will not have an adverse effect upon their performance of duties for Certsure or provide any other workplace advantage.
  • Not misuse Certsure’s name or use it in relation to any personal interests or for personal gain.
  • Disclose immediately to their manager any activity which is or gives the appearance of a conflict of interest with Certsure’s business, or any interests that might impact on business relationships, or which could interfere with their ability to carry out their employment or duties in good faith and with integrity. An example of this would be disclosing any activities whereby family members or friends are engaged with any type of work for Certsure’s business.
  • Follow the disclosure process outlined below and obtain prior written approval in relation to any potential conflict of interest.

Disclosure process:

• • Any potential conflict of interests must be raised with managers in the first instance, and written approval must then be received from a member of the operational leadership team.
  • Matters will be escalated to the senior leadership team for further consideration where considered appropriate.
  • The operational leadership team must disclose all potential conflict of interests to Human Resources, who will provide a response in writing for managers to issue to workers as soon as reasonably practicable.
  • Human Resources will maintain a central register of all declared conflict of interests, stating whether approval has been given.

3. 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. This policy does not prohibit normal, appropriate and proportionate hospitality (given and received) to or from third parties. The giving or receiving of gifts is not prohibited, if the following requirements are met:

(a) it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits.
(b) it complies with local law.
(c) it is given by you on our express instructions in our name, not in your name.
(d) it does not include cash or a cash equivalent (such as gift certificates or vouchers).
(e) it is appropriate in the circumstances (e.g., small gifts to be given at Christmas time).
(f) taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time; and
(g) it is given openly, not secretly.

Gifts should not be offered to or accepted from government officials or representatives, or politicians or political parties, without prior approval from the Managing Director.

We appreciate that the practice of giving business gifts varies between countries and regions of the UK and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable, justifiable and proportionate. The intention behind the gift should always be considered.

4. What is not acceptable?

(a) give, promise to give, or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.
b) 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.
(c) accept payment from a third party that you know, or suspect is offered with the expectation that it will obtain a business advantage for them.
(d) accept a gift or hospitality from a third party if it is known or suspected that it is offered or provided with an expectation that a business advantage will be provided by the worker or Certsure in return. Gifts, gratuities, entertainment of anything of value, beyond levels set by the Senior Leadership Team, shall not be accepted by employees or their family members from any person who has business dealings with Certsure. Where the value of any item exceeds £50 this should be notified to the Finance Director who must enter the transaction into the Corporate Hospitality Register.
(e) threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
(f) engage in any activity that might lead to a breach of this policy.

5. Facilitation Payments and Kickbacks

Certsure does not make, and will not accept, facilitation payments or kickbacks of any kind. Similarly, workers must not make or accept such payments. Any suspicions, concerns or queries regarding payment of any kind should be raised with a senior manager.

6. Donations

Certsure will only make charitable donations that are legal and ethical under local laws and practices. No donation may be offered or made without prior approval from a senior manager.

7. Modern Slavery Act

Whilst Certsure does not meet the criterion which necessitates the production of an annual slavery and human trafficking statement, Certsure share the same ethos as that outlined within the Act and are committed to ethical procurement and transparency within our supply chain.

8. Your Responsibility

Workers must notify a senior manager as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if a client/customer or potential client/customer offers something to gain a business advantage with a worker or Certsure or indicates that a gift or payment is required to secure their business. If workers are unsure whether a particular act constitutes bribery or corruption, or if they have any other queries, these should be raised with a senior manager immediately.

Any Certsure employee who breaches this policy may face disciplinary action which could result in dismissal.

Certsure are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If workers believe they have suffered any such treatment, they should inform their line manager or a senior manager immediately.

9. Who is responsible for the Policy?

Management at all levels are responsible for ensuring those reporting to them are aware of and understand this policy and are given adequate training. Management are accountable for communicating the core principles of this policy and ensuring that workers and other parties fully understand them.

All workers should ensure that they take the time to read and understand this policy. Any misuse should be reported to the People Director. Questions regarding the content or application of this policy should be directed to Human Resources.

10. Training and Communication

Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

11. Record Keeping

Certsure must ensure that all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure. No accounts must be kept “off-book” to facilitate or conceal improper payments.

12. Monitoring and Review

This policy will be monitored periodically by Certsure to judge its effectiveness and will also be updated in accordance with changes in the law.

Approval and Ownership