1. ABOUT US AND THIS POLICY
1.1 We are a not-for-profit UK company funded by the owners of several UK offshore wind farms. It is our policy to conduct all of our business in an honest and ethical manner. We take 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.
1.2 We manage funding donated by offshore wind farm owners, provided for the purpose of supporting and developing commercial fishing activities and financing and supporting community projects that are of direct benefit to the fishing industry that operate in the same areas as the wind farms. The process by which we scrutinise applications for any grant or funding is open and transparent and can be found on our website here.
1.3 Any employee who breaches this anti-bribery policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.
1.4 This policy will be reviewed regularly.
2. WHO MUST COMPLY WITH THIS POLICY?
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
3. WHAT IS BRIBERY?
3.1 Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
3.2 Bribery includes offering, promising, giving, accepting or seeking a bribe.
3.3 All forms of Bribery are strictly prohibited and our decision making process shall not be influenced or affected by any such activity.
3.4 We will not:
(a) give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
(b) accept any offer from a third party that we know or suspect is made with the expectation that we will provide any advantage for them or anyone else in relation to our giving of funding or grants or anything else; or
(c) give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.
3.5 If we suspect that a Bribe has been offered or suggested during any application for funding we shall immediately, at our sole discretion, reject such an application and if we deem appropriate report this to any relevant authority or authorities.
4. GIFTS AND HOSPITALITY
4.1 This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment.
4.3 Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not in any individual’s name.
4.4 Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.
5.1 We keep a written record of all hospitality or gifts given or received.
5.2 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers are to be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.