Anti-Bribery Policy
1. Introduction
1.1 Purpose
This Anti-Bribery Policy outlines First Call Nursing LTD’s (“The Company”) dedication to preventing bribery and corruption in every aspect of its operations. It provides a framework to ensure full compliance with the UK Bribery Act 2010 and other applicable anti-bribery laws and regulations.
1.2 Scope
This policy is applicable to all employees, contractors, consultants, agents, and anyone acting on behalf of First Call Nursing LTD (collectively referred to as “Personnel”). It also applies to business partners, clients, and any third parties engaged by the Company.
2. Policy Statement
2.1 Our Commitment
First Call Nursing LTD is committed to operating with the highest levels of honesty, integrity, and transparency. We strictly prohibit all forms of bribery and corruption, both within our internal operations and in our dealings with external entities. All Personnel are expected to adhere to these principles and report any suspected or actual incidents of bribery or corruption.
2.2 Legal Compliance
The Company is fully compliant with the UK Bribery Act 2010 and all other relevant anti-bribery laws. It is the duty of all Personnel to familiarize themselves with these laws and adhere strictly to their provisions.
2.3 Zero Tolerance
First Call Nursing LTD maintains a zero-tolerance stance on bribery and corruption. Any Personnel found engaging in such activities will face disciplinary actions, which may include termination of employment or contractual agreements. The Company may also report such violations to the relevant legal authorities.
3. Definitions
3.1 Bribery
Bribery involves offering, promising, giving, accepting, or soliciting any undue advantage, whether financial or otherwise, with the intent to influence the actions, decisions, or behavior of an individual in a professional or business context.
3.2 Facilitation Payments
Facilitation payments are minor payments made to expedite routine actions or services that an individual or entity is legally entitled to.
4. Prohibited Activities
4.1 Bribery and Corruption
The following activities are strictly prohibited:
• 4.1.1 Offering, promising, giving, or receiving any form of bribe, kickback, facilitation payment, or other improper advantage, directly or indirectly, to or from any individual or entity, including public officials, clients, suppliers, or competitors.
• 4.1.2 Using intermediaries, such as agents or consultants, to facilitate or disguise acts of bribery or corruption.
• 4.1.3 Engaging in any behavior that could be perceived as compromising the Company’s integrity or fair competition.
• 4.1.4 Accepting gifts, hospitality, or favors intended to influence or create an obligation beyond standard business practices.
• 4.1.5 Maintaining unreported or unrecorded accounts, funds, or assets intended for bribery or corrupt purposes.
• 4.1.6 Participating in political contributions, donations, or support that may be interpreted as bribery or corruption.
4.2 Gifts and Hospitality
The Company acknowledges that the exchange of gifts and hospitality is common in business. However, all Personnel must exercise caution to avoid compromising the Company’s integrity. Any gifts or hospitality must:
• 4.2.1 Be of modest value and align with local customs, norms, and applicable laws.
• 4.2.2 Not be exchanged with the intention of influencing business decisions.
• 4.2.3 Be properly documented in the Company’s records.
5. Due Diligence
5.1 Business Partners
The Company will conduct thorough due diligence on all business partners, including clients, suppliers, and intermediaries, to evaluate their integrity, reputation, and compliance with anti-bribery laws. The level of due diligence will match the risk associated with the relationship.
6. Reporting and Whistleblowing
6.1 Reporting Obligations
All Personnel are responsible for promptly reporting any suspicions or concerns related to potential bribery or corruption. This includes self-reporting if an individual recognizes their involvement in such activities. Reports should be directed to the designated contact within the Company.
6.2 Whistleblower Protection
The Company encourages open communication and provides a confidential and anonymous reporting mechanism for bribery or corruption concerns. Whistleblowers are protected from retaliation, and the Company will ensure their confidentiality to the fullest extent permitted by law.
7. Training and Awareness
7.1 Training Programs
The Company will offer regular training and awareness sessions to ensure that all Personnel are fully informed of their responsibilities under this policy. Training will be tailored to the specific roles and responsibilities within the Company.
8. Policy Review
8.1 Ongoing Review
This policy will be reviewed and updated periodically to ensure it remains effective and in line with evolving laws and regulations.
By following this Anti-Bribery Policy, we affirm our commitment to ethical business practices, maintaining stakeholder trust, and preventing all forms of bribery and corruption.