The VGC Group and its associated companies operate an ethical and open approach to the way we do business. We do not tolerate any form of unethical behaviour including acts of corruption, bribery or unfair anti-competitive business practices.
This policy applies to all employees and officers of the company, and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, the company (associated persons), within the UK and overseas. Every employee and associated person acting for or on behalf of the company, is responsible for maintaining the highest standards of business conduct.
While working on behalf of the VGC Group all employees and associated persons shall pursue our business interests with the highest degree of integrity at all times.
- You shall not accept, whether directly or indirectly, any bribe or incentive during the course of your duties.
- You should notify your line manager if you are offered a bribe or incentive.
- If you are offered a bribe or incentive from a client, supplier or any other entity in the course of your duties you must inform the group services director who will review the offer and decide whether it is appropriate. All items offered and declined will be recorded on a register which will be reviewed on a regular basis. All offers are deemed to belong to the company and whether you are permitted to avail yourself of an opportunity will be at the company’s discretion.
- You shall not offer whether directly or indirectly any bribe or incentive during the course of your duties.
- You should notify your line manager should you become aware of any colleague or third party who has offered or received a bribe or incentive. This can be done in the strictest of confidence.
- You should obtain prior approval from your line manager of all gifts or entertainment provided to others. You will need to provide the receipts thereof to the Accounts department.
- Failure to comply with this policy will be dealt with in accordance with our disciplinary procedures and, depending on the circumstances, may result in dismissal on the grounds of gross misconduct.
- A criminal offence will be committed under the Bribery Act 2010 if an employee, or associated person acting for or on behalf of the company offers, promises, gives, requests, receives or agrees to receive bribes or offers, promises or gives a bribe to a public official with the intention of influencing that official in the performance of his/her duties.
A bribe is defined in the Bribery Act 2010 as “a financial or other advantage” offered, promised or given to induce a person to perform a relevant function or activity improperly, or to reward them for doing so. This could include but is not limited to a gift, reward, entertainment or incentive.
Laurence McKidd, managing director