1. Purpose
Comex Services Ltd. is committed to conducting its business ethically, with integrity, and in compliance with all applicable laws, including the UK Bribery Act 2010. This policy outlines our zero-tolerance approach to bribery and corruption and ensures all employees, contractors, and third parties acting on our behalf understand their responsibilities in preventing and reporting unethical behaviour.
2. Scope
This policy applies to all employees, directors, contractors, consultants, agents, suppliers, and any third party acting on behalf of Comex Services Ltd.
3. Policy Statement
Offering, giving, soliciting, or receiving bribes in any form.
Engaging in corrupt practices to gain business, financial, or personal advantages.
Accepting gifts, hospitality, or other benefits that could influence or appear to influence business decisions.
4. Definitions
Bribery Offering, giving, receiving, or soliciting something of value to influence a business decision.
Corruption Abuse of entrusted power for personal or private gain.
Facilitation Payments Small, unofficial payments to speed up routine tasks, which are also prohibited.
5. Responsibilities
Employees All employees are responsible for upholding this policy. Any suspicion of bribery or corruption must be reported immediately.
Management Managers must ensure all team members understand and comply with this policy.
Third Parties Any individual or organization acting on behalf of Comex Services Ltd. must comply with this policy and relevant laws.
6. Gifts and Hospitality
Comex Services Ltd. recognizes that modest gifts and hospitality can be part of normal business relationships. However:
Gifts or hospitality must never be offered or accepted if they could influence, or be perceived to influence, a business decision.
All gifts or hospitality above a value of £50 must be approved by management and recorded in the Gifts and Hospitality Register.
7. Reporting and Whistleblowing
Any suspicion of bribery or corruption must be reported immediately to Pacer Richardson.
Reports will be handled confidentially, and employees raising concerns in good faith will be protected under our whistleblowing policy.
8. Training and Communication
Comex Services Ltd. will provide regular training to ensure all employees understand the principles of this policy.
This policy will be clearly communicated to all employees, contractors, and business partners.
9. Breaches and Disciplinary Action
Breaches of this policy are taken seriously and may result in disciplinary action, up to and including dismissal.
Violations may also result in legal action under the UK Bribery Act 2010.
10. Monitoring and Review
This policy will be reviewed annually to ensure its effectiveness and compliance with legal requirements.
Contact for Questions
For questions about this policy or further guidance, please contact Pacer Richardson.