POLICY STATEMENT

It is the policy of Ecoserve Cleaning to conduct business in an honest and ethical manner. As part of that, the company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all 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.

Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and if we are found to have taken part in corruption we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.

PURPOSE

The purpose of this policy is to publicly communicate to third parties our position on bribery and corruption. Workers should always refer to our internal policy. In this policy, third party means any individual or organisation that comes into contact with us, and includes 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.

SCOPE AND APPLICABILITY

all individuals working at all levels and grades, including partners, senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as workers in this policy); and

Third parties. Where we engage with third parties, we will undertake appropriate steps to ensure that they comply with the principles set out in this policy

WHAT IS BRIBERY?

A bribe is an inducement or reward offered, promised, or provided to improperly gain any commercial, contractual, regulatory, or personal advantage, which may constitute an offence under the Act 2010.

The Company may also be liable under the Act if it fails to prevent bribery by an associated person (including, but not limited to Workers) for the company’s benefit.

WHAT IS NOT ACCEPTABLE?

(a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or the company will improperly be given a business advantage, or as a reward for a business advantage already improperly 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 where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;

(d) accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by the Firm in return;

(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.

FACILITATION PAYMENTS AND KICKBACKS

We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.

CHARITABLE DONATIONS AND SPONSORSHIP

Ecoserve Cleaning only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with the company’s internal policies and procedures.

RESPONSIBILITIES AND RAISING CONCERNS

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Workers are required to notify the Firm as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee Workers if they breach this policy

TRAINING AND COMMUNICATION

Training on this policy is provided for all Workers and our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors, and business partners.

MONITORING AND REVIEW

The company monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy, and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to provide assurance that they are effective in countering any risks of bribery and corruption.

All Workers are aware that they are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing

Operations Director – Ecoserve Cleaning Ltd – 16th January 2021