Anti Bribery and Corruption Policy

 

 

  1. What does our policy cover?

 

  1. This anti-bribery and anti-corruption policy set out the responsibility of anyone working for Fast UK Parcel (in any capacity) regarding observing and upholding our zero-tolerance position on bribery and corruption.

 

  1. This policy sets out to act as a source of information and guidance for employees, consultants, contractors, and sub-contractors of Fast UK Parcel, to help to identify and addressing any issues related to Bribery and Corruption.

 

2.Policy Statement

 

  1. Fast UK Parcel is committed to conducting business in an honest, transparent, and ethical manner, thus adopting zero tolerance to bribery and corruption and ensuring that the appropriate systems are implemented and in place to recognize and prevent bribery and corrupt activities. We are fully committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

 

  1. In compliance with UK laws relating to Anti Bribery and Corruption, mostly covered by the Bribery Act 2010, Fast UK Parcel understands that any breach of this act is punishable with unlimited fines and up to 10 years imprisonment and commits to uphold our legal responsibilities in accordance with the terms of the policy.

 

  1. Fast UK Parcel will constantly uphold all laws relating to anti-bribery and corruptions in all the jurisdictions in which we operate. We are bound by the UK laws, including the Bribery Act 2010, regarding our conduct both at home and abroad.

 

3.Who is covered by this policy?

 

  1. This anti-bribery and corruption policy applies to all Fast UK’s employees, consultants, sub-contractors, and any other person associated with the company (including Third Parties), as well as to Officers, Trustees, subsidiaries or their employees, and Board and/or committee members at any level, whether located within or outside the UK.

 

  1. For this policy, the third party refers to any individual or organization our company works with and existing and potential clients, customers, suppliers, business associates, governments, and public bodies, including their advisors, representatives and officials, politicians, and public parties.

 

  1. Any arrangements made by Fast UK Parcel with a third party are subject to clear contractual standards and must include specific provisions that require the third party to comply with the minimum terms of this policy.

 

4.Definition of Bribery

 

  1. Bribery is an illegal practice defined by the act of offering, giving, promising, asking, receiving, accepting, agreeing with, or soliciting valuables or advantages that could induce or influence any action or decision.

 

  1. A bribe refers to any reward, inducement, compensation, or item of value offered to obtain commercial, contractual, regulatory, or personal gain or advantage.

 

  1. Bribery is not limited to the act of offering a bribe. Acceptance of bribery also consists of a breach of policy and must not be engaged in any form, be it directly, passively, or through a third party.

 

  1. Anyone working for the Fast UK in any capacity must not bribe a foreign public official anywhere in the world or accept bribes of any degree. If uncertain about whether something qualifies as a bribe, further advice from the compliance manager must be sought.

 

5.What is Not Acceptable

 

  • This section of the policy refers to the following four areas:

    • Gifts and hospitality

    • Facilitation Payments

    • Political Contributions

    • Charitable Contributions

 

  1. The general rule is that Fast UK’s employees and consultants are only permitted to accept gifts of low value and appropriate acts of hospitality, as long as these are in accordance with the following requirements:

 

  • The gift/act of hospitality is not made to influence the party to whom it is being given, obtaining or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.

  • The gift/act of hospitality is not offered with the suggestion that a return favour is expected.

  • The gift/act of hospitality is in full compliance with local law.

  • The gift/act of hospitality is offered in the company's name, not a person.

  • The gift/act of hospitality does not include cash or a cash equivalent (e.g. a voucher or gift certificate).

  • The gift/act is appropriate for the circumstances (e.g. giving small gifts around Christmas or a small thank you to a company for helping with a large project upon completion).

  • The gift/act is of appropriate value and type and given at an appropriate time, considering the reason for the gift.

  • The gift/act of hospitality is given/received openly, not secretly.

  • The gift/act of hospitality is not selectively given to a key or influential person, clearly to directly influence them.

  • The gift/act of hospitality is not above a certain excessive value (usually over £100).

 

  • The gift/act of hospitality is not offered to, or accepted by, a government official or representative or politician or political party without the prior approval of the company’s Compliance Manager.

 

  1. Where inappropriate to decline the offer of a gift or act of hospitality (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted as long as it is declared to the Compliance Manager, who will assess the circumstances.

  2. Fast UK Parcel recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions; therefore, definitions of what is acceptable and not acceptable will inevitably differ for each.

  3. The intention behind a gift or act of service offered should always be considered, and in case of uncertainty, the advice of the Compliance Manager should be sought.

  4. As good practice, gifts given and received should always be disclosed to the Compliance Manager. Gifts from suppliers must always be disclosed.

  5. The intention behind a gift or act of service offered should always be considered, and in case of uncertainty, the advice of the Compliance Manager should be sought.

  6. Fast UK parcel recognizes that facilitation of payments is a form of bribery that involves facilitating the performance of a public official for a routine governmental action and tend to be made by low-level officials to secure or speed up a certain duty or action; therefore, we will not accept or raise facilitation payments of any nature.

  7. Fast UK Parcel understands that kickbacks are typically made in exchange for a business favour or advantage; thus, we will not allow kickbacks to be made or accepted.

  8. Fast UK Parcel recognises that despite our strict policy on facilitation payments and kickbacks, the workforce may face a situation where refusing or avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under such circumstances, the following steps must be taken:

    • Keep any amounts to the minimum.

    • Ask for receipts detailing the amount and reason for payment.

    • Create a record concerning the payment.

    • Report the incident to the line manager.

5.11 - Political Contributions - Fast UK Parcel will not make donations or contribution, monetary or other, to support any political parties or candidates as we recognise this may be perceived as an attempt to gain business advantage.

  1. Charitable Contributions - Fast UK Parcel accepts and encourages donations, whether through services, knowledge, time, or direct financial contributions (cash or otherwise), to charities that are legal and ethical and agrees to disclose all charitable contributions made.

  2. Charitable Contributions – The workforce must be careful to ensure that charitable contributions are not used to facilitate or conceal acts of bribery.

 

  1. Charitable Contributions – Fast UK Parcel will ensure that all charitable donations made are legal and ethical under local laws and practices and that donations are not offered/made without the approval of the compliance manager.

6.Workforce responsibilities

  1. All employees, consultants, and subcontractors must ensure that they read, understood, and comply with the information contained within this policy and any training or anti-bribery and corruption information provided.

  2. All employees, consultants and sub-contractors are responsible for the prevention, detection, and reporting of bribery and any other forms of corruption and required to refrain from any activities that could lead to, or imply, a breach of this policy.

 

  1. Anyone with reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future must notify the compliance manager.

 

  1. Employees' breach of this policy will be punishable with disciplinary action and could face dismissal for gross misconduct. If a subcontractor breaches this policy, Fast UK Parcel will no longer maintain its offer of services. Any breach of this policy can lead to termination.

 

7.Raising concerns

 

  1. This section of the policy covers three areas:

 

  • How to raise a concern

  • What to do if you are a victim of bribery or corruption

  • Protection

 

  1. How to raise a concern – In case of suspicions that there is an instance of bribery or corrupt activities occurring concerning Fast UK Parcel, the workforce are encouraged to raise their concerns as soon as possible. In case of uncertainty about whether a certain action or behaviour constitutes bribery or corruption, advice must be sought from the line manager, compliance manager, director, or the Head of Governance and Legal.

 

  1. Fast UK Parcel will familiarize all workforce with its whistleblowing procedures to allow any concerns to be vocalized swiftly and confidentially.

 

  1. What to do if you are a victim of bribery or corruption –Anyone that has been offered a bride asked to make one, suspects they might be offered or asked for a bribe in the near future, or have reason to believe they are a victim of another corrupt activity, must report their concerns to the compliance manager as soon as possible.

 

  1. Protection – Fast UK Parcel understands that when refusing to accept or offer a bribe or reporting any concerns relating to bribery and corruption, the workforce may feel worried about

 

Potential repercussions; therefore, Fast UK Parcel will support anyone who raises concerns in good faith under this policy, even if the outcome of the investigation finds that they were mistaken.

 

  1. Fast UK Parcel will ensure that no one suffers any detrimental treatment due to refusing to accept or offer a bribe or voicing their concerns about a potential act of bribery or corruption.

 

  1. If anyone who has reported an instance of bribery or corruption, or voiced their concerns, believes to have been subjected to unjust treatment due to complying with the terms of this policy, this must be reported to the line manager or compliance manager immediately.

 

 

8.Training and communication

 

  1. Fast UK Parcel will provide training on this policy as part of the induction process for everyone engaging with the company (as appropriate). The workforce will also receive regular, relevant training on how to adhere to this policy and shall be asked to confirm that they will comply with this policy formally.

 

  1. Fast UK Parcel’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, sub-contractors, business partners, and any third parties at the outset of business relations and as appropriate thereafter.

 

  1. Fast UK parcel will provide relevant anti-bribery and corruption training to employees, contractors, sub-contractors, etc. We feel their knowledge of how to comply with the Bribery Act 2010 needs to be enhanced. As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities.

 

9.Record Keeping

  1. Fast UK Parcel will keep detailed and accurate financial records and ensure the appropriate internal controls are in place to act as evidence for all payments made. Any gifs or acts of hospitality given or received shall be declared and logged accordingly, including the amount and reason, and are subject to managerial review.

 

 

10.Monitoring and reviewing

  1. Fast UK parcel’s compliance manager is responsible for monitoring and maintaining the effectiveness of this policy and will review its suitability, adequacy, and effectiveness regularly and implement any changes whenever necessary.

  2. Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure their effectiveness in practice.

 

  1. Any need for improvements shall be applied as soon as possible. Employees, consultants, and sub-contractors are encouraged to offer their feedback on this policy and offer any suggestions they may have on how it can be improved. Feedback and suggestions should be addressed to the compliance manager.

  2. This policy does not form part of the contract of employment, and the company may amend it at any time to improve its effectiveness at combatting bribery and corruption.