Bloomsbury Surveyors Bribery and Corruption Policy

1. Introduction

Bloomsbury Surveyors is committed to conducting business with integrity, transparency, and in compliance with all applicable laws. This policy outlines the company's stance on preventing, identifying, and addressing bribery and corruption in all its forms within the organisation and its business dealings.

2. Scope

This policy applies to all employees, whether permanent, temporary, or contract, as well as consultants, contractors, agents, and any other individuals or entities acting for or on behalf of the company.

3. Policy Statement

Bloomsbury Surveyors strictly prohibits:

• Bribery: Offering, promising, giving, accepting, or seeking a bribe in any form, whether cash or any other inducement, to or from any person or company to gain commercial, contractual, regulatory, or personal advantage.
• Corruption: Any form of corrupt practice, including embezzlement, nepotism, fraud, or collusion.

4. Compliance with Laws

Bloomsbury Surveyors will:

• Adhere to all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, including the UK Bribery Act 2010.
• Keep accurate and updated financial records and have appropriate internal controls in place that will evidence the business reason for making payments to, and receiving payments from, third parties.

5. Employee Responsibilities

All employees must:

• Ensure that they read, understand, and comply with this policy.
• Refrain from engaging in any form of bribery or corrupt practices.
• Report any bribery or corruption offers or solicitations they encounter to their supervisor or compliance officer.

6. Reporting Violations

Employees are encouraged to raise concerns about any instance of malpractice at the earliest possible stage. Reports can be made anonymously and will be treated confidentially. Retaliation against individuals who report wrongdoing in good faith will not be tolerated.

7. Management Responsibilities

Senior Management must ensure that:

• They set an example by their own conduct in accordance with this policy.
• Bribery and corruption risks are assessed, monitored, and managed effectively.
• Adequate resources and training are provided to employees to understand and implement this policy.
• They monitor compliance and deal with any violations appropriately.

8. Training and Communication

Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors, business partners, and any third parties at the outset of our business relationship with them and as appropriate thereafter.

9. Policy Review

This policy will be reviewed and updated regularly to ensure that it meets the requirements of the law and reflects best practice. Changes to the policy will be communicated in a timely manner to all staff.