Reason for the Policy

The reason for this policy is to set out what we must all do to help prevent bribery in all its forms. A bribe may include any payment, benefit or gift offered with the purpose of influencing a decision or outcome.
The policy is not designed to stop gifts; hospitality or entertainment being given or received.  It continues to be acceptable as long as it occurs as part of normal business activity following the guidelines of the policy.

Who Must Comply
This policy applies to all individuals working within SDPC (NW) Ltd including Directors, whether permanent or temporary. It is also expected that all self-employed individuals working on sites will comply with the policy, it is also expected that companies working with SD Painting in whatever capacity will act in accordance with the standards set out in this policy.

How You Comply
You must read and follow the requirements of the policy. You must also notify the Bribery Act Compliance Officer (Jay Parlane) as soon as possible if you believe that a conflict with this policy has occurred or may occur in the future.

What Happens if You Do Not Comply?
Employee – Subject to the company’s disciplinary procedure and any breach may be deemed as gross misconduct. Possible criminal conviction – an offence under the act can result in a fine and/or up to 10 years’ imprisonment.
SDPC (NW) Ltd – if the act is breached the company will be liable to prosecution and can result in a fine.

What You Cannot Do
Under no circumstances must you:
• Give, promise to give or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received or to reward a business advantage already given.
• Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain business advantage for them.
• Solicit or try to solicit any gift or hospitality from a third party.

• Make any unofficial ‘facilitation’ payments to officials in order to obtain permissions of any type (facilitation payments = ‘back-hander’s)

Checking out Suppliers & Partners – Due Diligence
A process will be in place to ensure our Suppliers & Business Partners are compliant in the requirements of the Bribery Act. This will be by inclusion in any future contracts.

Gifts, Hospitality & Entertainment
All SD Painting employees are expected to conduct themselves with integrity, impartiality and honesty at all times. You should not open yourself up to suspicion of dishonesty or conflict between work and private interests.
The giving and receiving of gifts, hospitality and entertainment is not prohibited as long as it is in the context of normal business activity and it is logged on the gift, hospitality and entertainment register.  Gifts, hospitality and entertainment given and received as a reward, inducement or encouragement for preferential treatment or inappropriate or dishonest conduct are strictly prohibited.

Gifts
The giving or receiving of gifts is not prohibited however they are subject to the following
criteria:
• They should be low value token gifts from an existing or potential supplier e.g. pen’s, calendars etc
• They are given to the company, not to an individual e.g. Chocolates
• They do not include cash/cash equivalent e.g. Vouchers
• They are appropriate to the circumstances e.g. a small gift at Christmas time
• They are not made with the intention of influencing any individual in relation to any circumstance
• They are given openly, not secretly

Hospitality and Entertainment
SD Painting employees may occasionally receive invitations from suppliers or others to corporate hospitality or entertainment events.

Questions to ask yourself before any hospitality or entertainment are accepted:
• What is the intent of the hospitality – is it to build a business relationship or for some other reason?
• How would it look if it were made public – would your action be questioned?

Hospitality or entertainment should only be accepted if:
• It could not be seen as been a reward, inducement or encouragement for preferential treatment
• Employees, from the ‘giver’, are in attendance
• It is not unduly lavish or extravagant
In all cases you must obtain the authorisation of your line manager before accepting.

Gift, Hospitality and Entertainment Register
All individuals have a responsibility to record details any gifts, hospitality and entertainment that they have given or received with a value of more than £/€25 and to ensure openness and transparency these must all be recorded in the Gift, Hospitality and Entertainment Register on a monthly basis.
Failure to record will be seen as inappropriate behaviour and could result in disciplinary action.

Political and Charitable Contributions
Employees are entitled to make personal contributions however they must not be made in order to gain any advantage in any business-related transaction.

Reporting issues & Bribery
Please ensure all issues are reported to the Bribery Act Compliance Officer (Jay Parlane).

Where to obtain advice
Any advice or guidance should be obtained from the Bribery Act Compliance Officer (Jay Parlane).