Control of Bribery & Corruption

Introduction

• This policy aims to lay down guidelines which will enable you to meet the aims and core values of Meridian Assurance while protecting you from misunderstanding or criticism.
• The principle of integrity requires that staff should not place themselves under an obligation that might influence, or be perceived to influence, the conduct of their duties. This means that the receipt of hospitality and gifts must be subject to clear restrictions and that any that are accepted must be declared and recorded.

Gifts

• You must not accept cash or personal gifts under any circumstances.
• Items of nominal value (i.e. approximately £25.00 or below) or free promotional pens, calendars, diaries and similar items may be accepted.
• Personal gifts may not be solicited under any circumstances.

Hospitality

• You should never accept lavish hospitality that could be interpreted as a way of exerting an improper influence over the way you carry out your duties.  Nor should you offer such hospitality to others on behalf of the Company.  The timing of hospitality in relation to procurement or purchasing decisions that the Company may be taking or tendering for is especially sensitive.  Above all, you must never solicit hospitality.  As a general rule you should not accept hospitality that the Company would not reciprocate in similar circumstances.
• Hospitality may be accepted for instances where:
• There is a genuine need to impart information or represent the Company.
• An event is clearly part of our industry or where the Company should be seen to be represented.
• The hospitality concerns attendance at a relevant conference or course where it is clear the hospitality is corporate rather than personal.
• Any hospitality provided should not be extravagant and a maximum figure of £50 per head should be used as a guideline.

Hospitality Ledger

• The Finance Director will maintain a Hospitality Register for the Company.  It will be the responsibility of individuals to ensure that the Finance Director is notified of all hospitality given or received.
• You may accept modest working meals and light refreshments without making any declaration.

Accept / Decline Hospitality

• Before accepting any hospitality, approval should be sought from your line manager.  You should contact your line manager if you are unsure as to whether or not you should accept a gift or hospitality.
• When you have to decline a gift or hospitality, you should be courteous but firm and draw the attention of the person making the offer to the existence of this policy.

Breaches of the Policy

• Please be aware that failure to adhere to this policy may result in disciplinary action.
• Inevitably some issues will affect senior members of staff more than others and some breaches of the policy may be regarded more seriously for those in such positions.