General

This document is only applicable to employees of Blue Ring Digital Services Ltd.

"Bribery Policy" refers to this Bribery Policy.

"You", "Your" refers to You the employee of Blue Ring Digital Services Ltd.

"We", "Us", "Our", "Blue Ring Digital Services Ltd" refers to Blue Ring Digital Services Ltd.

We will try to keep everything in this document as straightforward as possible, but if there’s anything You don’t understand, please get in touch with Us.

The headings in this Bribery Policy are for convenience only and shall not affect their interpretation.

The masculine shall include the feminine and the neuter and the singular the plural and vice versa.

If any provision or part of any provision of this Bribery Policy is found by a court or other competent authority to be void or unenforceable, such provision or part of a provision shall be deleted from these Bribery Policy and the remaining provisions or parts of the provision shall continue to be in full force and effect.

Overview

The purpose of the Bribery Policy is to set Our stance on bribery and to provide guidance on what to do if You experience or witness bribery whilst working for, or providing services on our behalf. This Bribery Policy will apply to all ‘associated persons’ of Blue Ring Digital Services Ltd. Meaning anyone providing services for or on behalf of Blue Ring Digital Services Ltd, including (but not limited to) employees, temporary workers, contractors and sub-contractors of Blue Ring Digital Services Ltd.

Policy Background

The Bribery Act 2010 came into force on 1 July 2011 and replaced all existing anti-bribery laws in the UK. This act created four offences of bribery:-

  1. Giving bribes; 
    • Offence: To offer, promise or give a bribe to create or reward improper performance.
  2. Receiving bribes;
    • Offence: To request, agree to receive or accept a bribe.
  3. Bribing a foreign public official; 
  4. Corporate offence of failing to prevent bribery;
    • Offence: Failure to prevent a bribe being paid, or the intent of a bribe being paid, for on the company’s behalf, by an associated person performing services for the company.
    • Defence: The Company must prove that it had ‘adequate procedures’ in place to prevent bribery on its behalf.

Giving and Receiving Bribes

As detailed in Our , You are absolutely forbidden to give or receive any bribes or give or receive other payments or things of value for any corrupt purpose, either in Your own name or on behalf of Blue Ring Digital Services Ltd.

Equally, Your family members must not receive any payments, favours or services in relation to any matters that concern Your employment. Payments for goods and services must follow any applicable trade terms, reflect the fair value of such goods or services and are fully accounted for.

Bribing a Foreign Public Official

You must also ensure that payments are not made to government officials for any improper purpose. You must always abide by the laws of the country in which You are located or conduct business.

Reporting Instances of Bribery

If You have a genuine concern regarding the giving or receiving of bribes, You are encouraged to come forward with any information if You feel it is appropriate to do so. In the first instance, please raise this with Your line manager, but if circumstances make this inappropriate, please approach a member of the Senior Leadership Team.

All concerns will be investigated and appropriate action taken. For more information, please see Our .

Hospitality and Gifts

It is appreciated that appropriate hospitality and business gifts can generate goodwill and improve working relationships. However, it is important that You avoid situations that may interfere, or appear to interfere, with Your integrity or the impartial performance of Your duties.

We want to ensure that all hospitality and gifts offered by Our supply base are used in the right way, rewarding the right people for the right objectives. You are also advised, for completeness, to maintain Your own record of invitations/ gifts accepted and declined in case You are ever asked to demonstrate good judgement over those invitations accepted.

Any offers of hospatality or gifts must not exceed an individual value of £25.

Monitoring and Review

To ensure compliance with the above, We will on an annual basis:

  • Review and update all Our polices where applicable;
  • Request that all senior managers make a declaration of compliance with the , providing an explanation if a declaration cannot be made;
  • Request that all senior managers, as part of the declaration of compliance with the , confirm that they ask their direct reports, on an annual basis to read this Bribery Policy.

CHANGES TO Bribery Policy

This Bribery Policy replaces all previous versions. We reserve the right to change the Bribery Policy at any time.