Preamble
Focus Awards Limited (the “Company”) is a highly respectable and recognizable organisation. It has gained its name and reputation among its competitors and consumers through its commitment to conducting business according to moral, ethical, and legal standards. The Company does not allow or tolerate any kind of bribery and corruption.
This Anti-Bribery and Corruption Policy (the “Policy”) discourages and prohibits any kind of bribe or corrupt practice with any kind of stakeholder, including offering, promising, or providing any kind of means or value to any stakeholder, including customer, government official, business partner, or a third party to induce any improper action in relation to our business.
Objective
This Policy outlines the Company’s moral and legal responsibility to counter bribery and corruption and provide tools and methods to keep check and balance on such practices.
Corruption
For the purpose of this Policy, bribery offences include bribes, kickbacks, extortions, either active or through inducement of any kind.
Penalty
Violation of this Policy is unacceptable. Any employee of the Company found to be in violation of this Policy may face severe civil and criminal penalties in addition to disciplinary proceedings.
Scope
This Policy applies to all the employees, directors, officers, and any third party directly engaged with our business. Further, the Policy applies to any subsidiary, branch office, or liaison office of the Company, regardless of its location.
Applicable Laws
This Policy is governed by the anti-corruption and anti-bribery laws of the United Kingdom.
Prohibition of Bribery
- The company’s employees are prohibited from offering, promising, or sanctioning any kind of payment or inducement to civil or government officials to secure improper business advantage or influence bureaucratic work.
- The Company prohibits employees from taking or receiving any gain, inducement, or advantage through improper means from any private entities.
Employees must obtain approval from the Company to advance any item of real or intrinsic value to any government official or private entity.
Provision of any kind of travel, gifts, cash, or meals to any government official or any person in exchange for any gain or advantage is prohibited.
Use of donations for any unfavourable gain or to influence any person is strictly prohibited. The Company will only sanction any kind of charitable gesture or donation through the proper procedure.
Sometimes it may be necessary to allocate or appropriate funds to promote or demonstrate Company products or services, but they must not be used to influence the normal functioning of such officer. Before appropriating such funds, approval from the CEO is necessary.
It is strictly prohibited to employ any government official, employee of a private entity, or their relatives to influence or gain an undue benefit. If the employment of such a person is considered necessary, prior approval from the CEO must be obtained.
Political contributions advanced to influence government officials are strictly prohibited.
Third parties associated with the Company, either directly or indirectly, are strictly prohibited from making any corrupt practice for or on behalf of the Company.
All payments to third parties in exchange for their services and contributions to the Company must be recorded appropriately and evidenced. Additionally, third parties interacting with a government official on behalf of the Company must be documented.
All third parties are obligated to do due diligence and approach the Company for explicit written permission to do so before engaging with government officials on behalf of the Company.
To ensure compliance with this Policy, the Company may conduct periodic audits of the Company and its associates. All employees, directors, officers, and stakeholders are obligated to cooperate with the audit process.
All directors, officers, employees, and stakeholders are obligated to report any violation of this Policy to the Company’s legal team. Failure to report such an incident constitutes a violation of this Policy and leads to disciplinary action.