1 Introduction: Policy Statement
1.1 Bribery is an inducement or reward offered, promised or provided to gain a personal, commercial, regulatory or contractual advantage. Bribery is a criminal offence and punishable for individuals by up to ten years’ imprisonment.
1.2 It is Theatre Scenery Supplies’ policy to conduct all 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 activities.
1.3 We are committed to the prevention, deterrence and detection of bribery. We aim to maintain anti-bribery compliance “business as usual”, rather than as a one-off exercise.
1.4 Those employed by or acting as agent for the Theatre Scenery Supplies will not pay bribes nor offer improper inducements to anyone for any purpose. Nor will those individuals accept bribes or improper inducements.
1.5 To use a third party as a conduit to channel bribes to others is a criminal offence. Theatre Scenery Supplies does not, and will not allow its staff or Members engage indirectly in or otherwise encourage bribery
2 Objective
2.1 The purpose of this policy is to:
(a) Set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption;
and,
(b) Provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.
3 What is Bribery
3.1 A “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, kickback, gifts, loans, fees, hospitality, services, discounts, the award of a contract, or any other commercial or personal advantage or benefit.
3.2 “Bribery” includes offering, promising, giving, accepting or seeking a bribe.
3.3 All forms of Bribery are strictly prohibited. If you are unsure about whether an act constitutes bribery, raise it with your manager.
3.4 Specifically, you must not:
- 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;
- accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
- 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 (even if these payments are common in certain countries); or
- threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
4 Conflicts of interest
4.1 All employees need to declare whether they have any personal interests that may conflict with the interests of the Theatre Scenery Supplies. Outside activities, additional employment or voluntary work can all create the potential for the interests of the employee to come into conflict with those of the Theatre Scenery Supplies.
4.2 Conflicts of interests can be damaging for the Theatre Scenery Supplies and those concerned, potentially leading to accusations of corruption and impropriety. In such situations the mere perception of wrongdoing can cause huge embarrassment, regardless of whether such accusations prove to be well founded or not.
4.3 Because declarations of interest are fundamental to the effective operation and reputation of the Theatre Scenery Supplies, failing to declare an interest will always be dealt with by the Theatre Scenery Supplies as a disciplinary matter and is likely to be deemed gross misconduct which may result in dismissal.
5 Gifts and hospitality
5.1 The acceptance of gifts and hospitality, even on a modest scale, may arouse suspicion and must be capable of public justification.
5.2 We must exercise discretion in offering and accepting gifts and hospitality. We consider how it might affect our relations with the party offering it and how elected Members, the public and other staff, might perceive it. If in any doubt we will discuss with our line manager.
6 Reporting your concerns
6.1 If in the course of your duties someone attempts to influence the outcome of a project, procurement or decision, report the matter to Theatre Scenery Supplies at theatrescenerysupplies@gmail.com.
6.2 If an incident of bribery, corruption, or wrongdoing is reported, the Theatre Scenery Supplies will act as soon as possible to evaluate the situation. The Theatre Scenery Supplies has clearly defined procedures for investigating fraud, misconduct and non-compliance issues and these will be followed in any investigation of this kind.
6.3 Members of the public can also raise their concerns in accordance with the Theatre Scenery Supplies’ Policy.
6.4 If you have any questions about this procedure, please contact: theatrescenerysupplies@gmail.com
Theatre Scenery Supplies 