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Anti-Bribery Policy

What is bribery?

  • A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely:

  • giving or offering a bribe;

  • receiving or requesting a bribe; or

  • bribing a foreign public official.

  • 121 Recruitment may also be liable under the Act if it fails to prevent bribery by an associated person (including but not limited to Workers) for the 121’s benefit.

 

Purpose

121 will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad.

 

Policy statement

It is the policy of 121 to conduct business in an honest and ethical manner. As part of that, 121 take a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.

 

Scope and applicability

This policy applies to all persons working directly for 121 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, sponsors, or any other person associated with us, wherever located (collectively referred to as “workers” in this Policy).

 

What is not acceptable?

  • It is not acceptable for any Worker (or someone on their behalf) to:

    • give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or the 121 will improperly be given a business advantage, or as a reward for a business advantage already improperly given;

    • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;

    • accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;

    • accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by 121 in return;

    • threaten or retaliate against another Worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

    • engage in any activity that might lead to a breach of this policy.

 

Facilitation Payments and Kickbacks

We do not make, and will not accept, facilitation payments or "kickbacks" of any kind.

 

Facilitation payments, also known as "back-handers" or "grease payments", are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in the UK, but are common in some other jurisdictions in which we operate.

 

Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with your Director.

 

Gifts, Hospitality and Expenses

This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:

  • establishing or maintaining good business relationships;

  • improving or maintaining our image or reputation; or

  • marketing or presenting our products and/or services effectively. 

 

The giving and accepting of gifts is allowed if the following requirements are met:

  • It is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

  • it is given in our name, not in your name; it does not include cash or a cash equivalent (such as gift certificates or vouchers);

  • it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas; and it is given openly, not secretly;

  • it complies with any applicable local law.

 

Record keeping

We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.

 

Responsibilities and raising concerns

  • The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

  • Workers are required to notify the 121 as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

  • Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee Workers if they breach this policy.

  • If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with info@121-recruitment-services.com

 

Training and communication

Training on this policy is provided for all Workers and our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors and business partners.

 

Monitoring and review

  • 121 monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to provide assurance that they are effective in countering any risks of bribery and corruption.

  • All Workers are aware that they are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

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