Anti-Bribery & Corruption Policy

Our position

NetFM UK Limited takes a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings, and to implementing and enforcing effective systems to counter bribery, in compliance with the Bribery Act 2010.

We sell to public bodies, financial institutions and large corporates whose procurement teams are rightly rigorous about this. Winning work on the merits of the product is the only way we want to win it.

Scope

This policy applies to all employees, directors, apprentices, contractors, agents, introducers, resellers and anyone else performing services for or on behalf of NetFM, wherever they are located. It applies equally to dealings with public officials and with private-sector customers and suppliers.

What is prohibited

You must never, whether directly or through a third party:

• Offer, promise, give, request, agree to receive or accept a financial or other advantage intended to induce or reward the improper performance of a function or activity.
• Offer or accept anything intended to influence a public official in the performance of their duties.
• Make a facilitation payment — a small unofficial payment to speed up a routine action. These are bribes under UK law regardless of local custom, and are prohibited without exception.
• Make or accept a kickback — a payment or benefit in return for a business favour or advantage.
• Make a political donation on behalf of NetFM.
• Make a charitable donation that is, or could reasonably appear to be, connected to winning or retaining business.
• Retaliate against, threaten or penalise anyone who refuses to pay or accept a bribe, or who raises a concern under this policy.

Gifts and hospitality

This policy does not prohibit normal and appropriate hospitality — a working lunch, a coffee, a reasonable meal at a conference. Hospitality is acceptable only where it is given openly and not in secret, is reasonable and proportionate, is not intended to influence a decision or obtain a business advantage, is not offered around the time of a tender or contract decision, and would not embarrass us if it were made public.

Cash and cash equivalents (including gift cards and vouchers) must never be given or accepted.

Any gift or hospitality given or received with a value over £50 must be declared to the Director of Operations and is recorded in our gifts and hospitality register. If you are unsure whether something is acceptable, ask before it happens rather than after. Many of our customers are public bodies with their own, stricter, rules — where a customer's policy is tighter than ours, theirs applies.

Third parties, introducers and resellers

A company can be liable under the Bribery Act for a bribe paid by someone acting on its behalf. We therefore carry out proportionate due diligence before appointing introducers, agents and resellers, we put the arrangement in a written agreement that includes anti-bribery obligations, and we pay commission that is proportionate, documented and payable only against a genuine service. We do not make payments to accounts in a country unconnected with the work, or to a person other than the contracted party.

Record keeping

We keep accurate and complete financial records with appropriate internal controls. All expenses relating to hospitality or gifts must be recorded and submitted in accordance with our expenses procedure, with the reason clearly stated. No accounts may be kept off the record.

Raising a concern

If you are offered a bribe, asked to make one, or suspect that bribery or corruption has occurred or may occur, report it as soon as possible to any director, or through our Whistleblowing Policy. Concerns can be raised in confidence. Nobody will suffer detriment for refusing to take part in bribery or for reporting a concern in good faith, even if it later proves unfounded — and we would far rather investigate ten false alarms than miss one real problem.

Consequences

Breach of this policy by an employee is a disciplinary matter and may result in dismissal for gross misconduct. We may terminate our relationship with any third party that breaches it. Individuals convicted under the Bribery Act 2010 face up to ten years' imprisonment and an unlimited fine; companies face an unlimited fine and exclusion from public procurement.

Responsibility and review

The Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations. The Director of Operations maintains the gifts and hospitality register and reviews this policy at least annually.