Anti-Bribery and Corruption Policy

The Company is committed to the prevention of bribery by those employed and associated with it and is committed to carrying out business fairly, honestly and openly with zero-tolerance towards bribery.

All employees have a responsibility to prevent, detect and report all instances of bribery.

Download our Anti-Bribery and Corruption Policy (PDF)

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Scope of this Policy

This policy applies to all employees and officers of R&M, and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, R&M (“associated persons”) within the UK and overseas. Every employee and associated person acting for, or on behalf of, R&M is responsible for maintaining the highest standards of business conduct. Any breach of this policy is likely to constitute a serious disciplinary matter and may cause serious damage to the reputation and standing of R&M.

It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to 10 years’ imprisonment and/or a fine. As an employer if R&M fails to prevent bribery it can face an unlimited fine, exclusion from tendering for public contracts, and reputational damage.

The policy covers:

  • The main areas of liability under the Bribery Act 2010.
  • The responsibilities of employee and associated persons acting for, on behalf of R&M.
  • The consequences of any breaches of this policy.

Bribery Act 2010

R&M is committed to complying with the Bribery Act 2010 in its business activities in the UK and overseas.

Under the Bribery Act 2010, bribery is offering, promising, giving or accepting a financial or other type of advantage to another person.

  • To induce them to act improperly in the performance of their functions.
  • Rewarding the or acting improperly.
  • Where the recipient would act improperly by accepting the advantage.

An advantage includes money, gifts, loans fees, hospitality, services, discounts, the award of a contact or anything else of value.

A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.

Corruption is the abuse of entrusted power or position for private gain.

A criminal offence will be confirmed under the Bribery Act 2010 if:

  • An employee or associated person acting for, or on behalf of, R&M offers, promises, gives, requests, receives or agrees to receive bribes.
  • An employee or associated person acting for, or on behalf of, R&M offers, promises or gives a bribe to a foreign public official with the intention of influencing that official in the performance of his/her duties (where local law does not permit or require such influence).
  • R&M does not have to defence that it has adequate procedures in place to prevent bribery by its employees or associated persons.

All employees and associated persons are required to comply with this policy, in accordance with the Bribery Act 2010.

What is Prohibited?

The Company expressly prohibits employees from offering, promising, giving, or requesting, agreeing to receive or receiving any financial or other advantage to another person or business with the intention of gaining an improper financial or other advantage.

The Company expressly prohibits the bribing of a UK or foreign public official in order to obtain or retain business or an advantage in the conduct of business.

This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or sub-contractors, agents or sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.

Records

Employees and, where applicable, associated persons, are required to take particular care to ensure that all company records are accurately maintained in relation to any contracts or business activities, including financial invoices and all payment transactions with clients, suppliers and public officials.

Due diligence should be undertaken by employees and associated persons prior to entering into any contract, arrangement or relationship with a potential supplier of services, agent, consultant or representative.

Employees and associated persons are required to keep accurate, detailed and up to date records of all corporate hospitality, entertainment or gifts accepted or offered.

Working Overseas

Principle

Employees and associated persons conducting business on behalf of R&M outside the UK may be at greater risk of being exposed to bribery or unethical business conduct than UK-based employees. Employees and associated persons owe a duty to R&M to be extra vigilant when conducting international business.

Procedure

Employees and associated persons are required to cooperate with R&M’s risk management procedures and to report suspicions of bribery to Human Resources and Compliance Manager.

While any suspicious circumstances should be reported, employees and associated personas are required particularly to report:

  • Close family, personal or business ties that a prospective agent, representative or joint-venture partner may have with government or corporate officials, directors or employees.
  • A history of corruption in the country in which the business is being undertaken.
  • Requests for cash payments.
  • Requests for unusual payment arrangements, for example via a third party.
  • Requests for reimbursements of unsubstantiated or unusual expenses.
  • A lack of standard invoices and proper financial practices.

If an employee or associated person is in any doubt as to whether or not a potential act constitutes bribery, the matter should be referred to Human Resources and Compliance Manager.

Facilitation Payments

Principle

R&M prohibits its employees or associated persons from making or accepting any facilitation payments. These are payments made to secure or speed up routine procedures (for example by a government official). They are more common overseas. Facilitation payments are distinct from an official, publicly available fast- track process.

Facilitation payments, or offers of such payments, will constitute a criminal offence by both the individual concerned and R&M under the Bribery Act 2010, even where such payments are made or requested overseas. Employees and associated persons are required to act with greater vigilance when dealing with government procedures overseas.


Procedure

Where a public official has requested a payment, employees or associated persons should ask for further details of the purpose and nature of the payment in writing. If the public official refuses to give these, this should be reported immediately to Human Resources and Compliance Manager.

If the public official provides written details, Human Resources and Compliance Manager will consider the nature of the payment. Local legal advice may be sought by R&M.

If it is concluded that the payment is a legitimate fee, for example part of a genuine fast-track process, or is permitted locally, R&M will authorise the employee to make the payment. You should always ask for a receipt which details the reason for the payment.

Where Human Resources and Compliance Manager considers that the request is for a facilitation payment, the employee or associated person will be instructed to refuse to make the payment and notify the public official that the employee or associated person is required to report the matter to R&M and the UK embassy.

R&M will seek the assistance of the relevant employee in its investigation and may determine that the matter should be referred to the prosecution authorities.

If an employee or associated person has any other concerns about the nature of a request for payment, he/she should report it to Human Resources and Compliance Manager using the reporting procedure set out in this policy and in accordance with R&M’s whistleblowing policy.

Corporate Entertainment, Gifts, Hospitality and Promotional Expenditure


Principle

Reasonable and proportionate hospitality, advertising, sponsorship and promotional or other similar business expenditure is recognised as an established and important part of doing business, however, hospitality, promotional and similar business expenditure can be used as bribes.

The Company expressly prohibits the giving and receiving of hospitality/business gifts and similar where the intention in doing so is to receive or confer an advantage in return for giving or receiving the hospitality/business gift or similar.


Procedure

All offers of business gifts should be referred to and agreed to by your Line Manager or Group Managing Director.

Business gifts should not be made without the permission of your Line Manager or Group Managing Director.

A record of all business gifts made and received and the reason for the gift should be retained.

All hospitality must be proportionate and reasonable and in line with the Company’s hospitality policy. Guidance should be sought from your Line Manager or Group Managing Director as to whether the planned hospitality is proportionate and reasonable.

Records should be maintained of all hospitality provided and accepted, including cost and reason for providing or accepting the hospitality.

Employees and, where applicable, associated persons must supply records and receipts, in accordance with R&M’s expenses policy.

Quid pro quo arrangements are expressly prohibited.

Cash gifts are expressly prohibited.

The provision or acceptance of entertainment of a sexual nature is expressly prohibited.

Acceptable hospitality and entertaining may include modest meals with people with whom the Company do business (such as providing a modest lunch after a meeting) or the occasional provision of or attendance at sporting or cultural events, provided that the intention is to build business relationships rather than to receive or confer an advantage.

The provision of small promotional gifts, such as diaries, pens or similar, will generally be regarded as acceptable.

Employees reviewing expense claims should be alert to the provision of hospitality/business gifts that may be construed as a bribe.

All concerns should be reported.

Where you develop or seek to develop new avenues for business or new contracts, or where the nature of the business changes, you should inform your Line Manager of this in order that due diligence and a risk assessment of the circumstances can be undertaken.

Where a business relationship with an external party is sought or newly established, or the nature of the relationship is changed, appropriate due diligence must be exercised to ensure that there are no circumstances giving rise to a concern. That external party must also be made aware of this anti-bribery policy.

Charitable and Political Donations

R&M considers that charitable giving can form part of its wider commitment and responsibility to the community. R&M supports a number of charities that are selected in accordance with objective criteria, following a risk assessment. R&M may also support fundraising events involving employees.

What practices are permitted?

This policy does not prohibit:

  • Normal and appropriate hospitality and entertainment with clients.
  • The use of any recognised fast-track process that is publicly available on payment of a fee.

Any such practices must be proportionate, reasonable and made in good faith. Clear records must be kept.

Risk Management

Principle

R&M has established detailed risk management procedures to prevent, detect and prohibit bribery.

R&M will conduct risk assessments for each of its key business activities on a regular basis and, where relevant, will identify employees or officers of R&M who are in positions where they may be exposed to bribery.

Procedure

R&M will identify high-risk areas, for example projects undertaken in high-risk countries, tenders for work and those working on high-value projects. Employees and associated persons are required to complete a bribery risk assessment form with Human Resources and Compliance Manager when commencing a new project.

R&M will:

  • Carry out a risk assessment to ascertain the risk of bribery.
  • Instigate procedures proportionate to that risk.
  • Have good internal controls and record-keeping.
  • Secure the commitment of all employees to the prevention and detection of bribery.
  • Develop a culture in which bribery is unacceptable.
  • Undertake due diligence procedures proportionate to the assessed risk of bribery.
  • Effectively communicate the anti-bribery policy to all employees.
  • Train all employees to recognise bribery so that they can avoid it and be alert to possible instances of bribery.
  • Have clear procedures on what to do should bribery be suspected.
  • Train all employees so that they are aware of what to do should they discover a possible instance of bribery.
  • Monitor and review the effectiveness of the bribery procedures and update them as necessary to ensure that they remain effective.

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

Reporting Suspected Bribery

Principle

R&M depends on its employees and associated persons to ensure that the highest standards of ethical conduct are maintained in all its business dealings. Employees and associated persons are requested to assist R&M and to remain vigilant in preventing, detecting and reporting bribery.

Anyone who has concerns regarding acts or potential acts of bribery should speak to their Line Manager in the first instance. If for any reason you are not able to speak to your Line Manager, you should contact Human Resources and Compliance Manager. Issues that should be reported include:

  • Any suspected or actual attempts at bribery.
  • Concerns that other employees or associated persons may be being bribed.Any suspected or actual attempts at bribery.
  • Concerns that other employees or associated persons may be bribing third parties, such as clients or government officials.

All reports will be treated in confidence, however if appropriate concerns can be reported anonymously.

Procedure

A form is available on the staff intranet or from the HR department to allow employees to record any incidents of suspected bribery. Any such reports will be thoroughly and promptly investigated by Human Resources and Compliance Manager in the strictest confidence. Employees and associated persons will be required to assist in any investigation into possible or suspected bribery.

Employees will also be required to comply with R&M’s Whistleblowing Policy.

Employees or associated persons who report instances of bribery in good faith will be supported by R&M. R&M will ensure that the individual is not subjected to detrimental treatment as a consequence of his/her report. Any instances of detrimental treatment by a fellow employee because an employee has made a report will be treated as a disciplinary offence. An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, employees and associated persons should not agree to remain silent. They should report the matter to Human Resources and Compliance Manager.

Penalties

The penalties for breaching the provisions of the Bribery Act 2010 include unlimited fines for the Company, imprisonment and unlimited fines for individuals.

Failure to follow the procedures mentioned in this policy may result in formal disciplinary action being taken against you, as set out in our disciplinary procedure


Action by R&M

R&M will fully investigate any instances of alleged or suspected bribery. Employees suspected of bribery may be suspended from their duties while the investigation is being carried out. R&M will invoke its disciplinary
procedures where any employee is suspected of bribery, and proven allegations may result in a finding of gross misconduct and immediate dismissal. R&M may terminate the contracts of any associated persons,
including consultants or other workers who act for, or on behalf of, R&M who are found to have breached this policy.

R&M may also report any matter to the relevant authorities, including the Director of Public Prosecutions, Serious Fraud Office, Revenue and Customs Prosecutions Office and the police. R&M will provide all necessary assistance to the relevant authorities in any subsequent prosecution.

Review of Procedures and Training

R&M will regularly communicate its anti-bribery measures to employees and associated persons.

Human Resources and Compliance Manager will monitor and review the implementation of this policy and related procedures on a regular basis, including reviews of internal financial systems, expenses, corporate hospitality, gifts and entertainment policies.

Employees and those working for, or on behalf of, R&M are encouraged to contact Human Resources and Compliance Manager with any suggestions, comments or feedback that they may have on how these procedures may be improved.

R&M reserves the right to amend and update this policy as required. For the avoidance of doubt, this policy does not form part of any employee’s contract of employment.

Issue Date: June 11
Sponsor: B Szklarska