Anti-Bribery Policy

All Bespoke Support Solutions representatives should play a key role in counter-fraud initiatives. This includes providing a corporate framework within which counter-fraud arrangements will flourish. This should provide a sound defence against internal and external abuse of funds. 
‍
The definition of Bribery and fraud is as follows:

1.1  Bribery and/or corruption is the offering, giving, soliciting or acceptance of an inducement or reward that may influence the action of another

1.2  Fraud encompasses an array of irregularities and illegal acts all of which are characterised by intentional deception with intent to make a gain or to cause a loss, or to expose another to risk of loss. It can be perpetrated by internal or external parties for the benefit of or to the detriment to Bespoke Support Solutions

The purpose of this Policy is to set out the main principles for countering bribery, corruption and fraud which are applicable, but not limited to Bespoke Support Solutions employees, agency staff and associates.

This policy applies to, but not limited to, employees, associates and agency staff.

The 2010 Bribery Act created various new offences, including an offence which can be committed by commercial organisations that fail to prevent persons associated with that organisation from committing bribery on their behalf. This applies regardless of whether the person works or commits the offence in the UK or any other country in which the organisation operates. However, it is a full defence for an organisation if it can prove that despite the bribery occurring, it has adequate procedures in place to prevent those persons associated with it from committing bribery. The organisation’s procedures must be proportionate to the bribery risks that it faces in relation to the nature, scale and complexity of the organisation. 

Bespoke Support Solutions is committed to the prevention of bribery by those but not limited to, employees, agency staff and associates carrying out its business fairly, honestly and openly, with zero-tolerance towards bribery. In order to ensure compliance with and enforcement of this policy and the rule of law, the role of Anti-Bribery Officer is held by the Company Secretary within Bespoke Support Solutions. 

This is achieved by:

• Carrying out a risk assessment to ascertain the risk of bribery. 
• Instigating procedures proportionate to that risk. 
• Having good internal controls and record-keeping.
• Securing the commitment of directors, managers and all employees to the prevention and detection of bribery.    
• Developing a culture in which bribery is unacceptable.     
• Undertaking due diligence procedures proportionate to the assessed risk of bribery.
• Effectively communicating the anti-bribery policy to all staff.
• Training all staff to recognise bribery so that they can avoid it and be alert to possible instances of bribery.
• Having clear procedures on what to do should bribery be suspected.
• Training all staff so that they are aware of what to do should they discover a possible instance of bribery.
• Monitoring and reviewing the effectiveness of the bribery procedures and updating them as necessary to ensure that they remain effective.

Bespoke Support Solutions expressly prohibits any person employed or engaged by Bespoke Support Solutions from offering, promising or giving any financial or other advantage to another person where it is intended that the advantage will bring about improper performance by another person of a relevant function or activity, or that the advantage will reward such improper performance. 

Bespoke Support Solutions prohibits any person employed by or associated with it from offering, promising or giving any financial or other advantage to another person where it is believed that the acceptance of the advantage offered, promised or given in itself constitutes the improper performance of a relevant function or activity.

Bespoke Support Solutions expressly prohibits any person employed by or engaged by Bespoke Support Solutions, from requesting, agreeing to receive or receiving any financial or other advantage with the intention that a relevant function should be performed improperly as a result of the advantage or as a reward for performing the relevant function improperly.
‍
The improper performance of a relevant function in anticipation of receiving financial or other advantage is also prohibited.

Bespoke Support Solutions expressly prohibits the bribing of a UK or foreign public official in order to obtain or retain business or an advantage in the conduct of business.

Relevant functions and activities are anyfunction of a public nature, any activity connected with the business, anyactivity performed in the course of a person’s employment and activityperformed by or on behalf of a body of persons where the person performing thatfunction or activity is expected to perform it impartially, in good faith, oris in a position of trust by virtue of performing it.

The Bribery Act 2010 does not seek to prohibit reasonable and proportionate hospitality, advertising, sponsorship and promotional or other similar business expenditure, as it is recognised that this constitutes an established and important part of doing business. However, hospitality, promotional and similar business expenditure can be used as bribes.

Bespoke Support Solutions expressly prohibits the giving and receiving of hospitality/business gifts and similar where the intention in doing so is to receive or confer an advantage in return for giving or receiving the hospitality/business gift or similar.

The following procedures should be adopted in relation to hospitality and business gifts:

• All offers of business gifts should be referred to the Anti-Bribery Officer (see section 4.0) and should only be accepted if clearance has been received.
• Business gifts should not be made without the permission of the Anti-Bribery Officer.
• A record of all business gifts made and received and the reason for the gift should be retained.
• All hospitality must be proportionate and reasonable and in line with Bespoke Support Solutions’s hospitality policy. Guidance should be sought from the Anti-Bribery Officer as to whether the planned hospitality is proportionate and reasonable.
• Records should be maintained of all hospitality provided and accepted, including cost and reason for providing or accepting the hospitality.  
• Quid pro quo arrangements are expressly prohibited.   
• Cash gifts are expressly prohibited.
• The provision or acceptance of entertainment of a sexual nature is expressly prohibited.

Acceptable hospitality and entertaining may include modest meals with people with whom we do business (such as providing a modest lunch before, during or after a meeting) or the occasional provision of or attendance at sporting or cultural events, provided that the intention is to build business relationships rather than to receive or confer an advantage.

‍The provision of small promotional gifts,such a diaries, pens or similar, will generally be regarded as acceptable.

‍Employees reviewing expense claimsshould be alert to the provision of hospitality/business gifts that may beconstrued as a bribe. All concerns will need to be reported.

Where you develop or seek to develop new avenues for business or new contracts, or where the nature of the business changes, you should inform your immediate manager of this in order that due diligence and a risk assessment of the circumstances can be undertaken.

Where a business relationship with an external party is sought or newly established, or the nature of the relationship is changed, appropriate due diligence must be exercised to ensure that there are no circumstances giving rise to a concern. That external party must also be made aware of this policy.

Facilitation payments are small bribes that are paid to speed up or facilitate government action. Although they are commonplace in some foreign countries, they are regarded as bribes and are illegal under the Bribery Act 2010.

Bespoke Support Solutions expressly prohibits facilitation payments of any sort. Any employee placed under pressure to make a facilitation payment should refer the matter to the Anti-Bribery Officer immediately.

Bespoke Support Solutions expressly prohibits the giving of donations to political parties.

Any charitable donation must be consistent with Bespoke Support Solutions policy on charitable donations and with the knowledge and consent of the Managing Director (MD). 

Bespoke Support Solutions expressly prohibits the making of charitable donations where the purpose of the donation is to secure an advantage. All charitable donations must be made without expectation of reward.

Bespoke Support Solutions employees have a responsibility to prevent, detect and report all instances of bribery, corruption and fraud. It therefore follows that we should all be alert to the possibility of such acts.

If you have any concerns regarding acts or potential acts of bribery, corruption or fraud you should speak to your immediate manager in the first instance. If for any reason you are not able to speak to your immediate manager, you should contact the Anti-Bribery Officer or Service Delivery Manager (SDM) without delay. 

All reports will be treated with the utmost confidentiality. However, concerns can be reported anonymously to the Anti-Bribery Officer or SDM.

All Bespoke Support Solutions employees will receive training on the anti-bribery policy to ensure that you understand both the policy and he procedures with which you are required to comply.

A copy of this policy will be held on the Bespoke Support Solutions Intranet system. All employees, contractors and associates of Bespoke Support Solutions are therefore required to:

• Familiarise yourself with the policy; amendments to the policy and procedures will be communicated to you without delay.

The Anti-Bribery Officer is responsible for monitoring and updating this policy. All questions and concerns should therefore ultimately be referred to this individual.

Bespoke Support Solutions will regard breaches of the anti-bribery policy with maximum seriousness.

Any such breach will be fully investigated any in accordance with the Disciplinary Policy & Procedures. If proven, this may lead to summary dismissal on the grounds of gross misconduct.