1. Statement
Live 2 Help Recruitment is committed to the highest standards of ethical conduct and integrity in its business activities in the UK. This policy sets out our position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. We will not tolerate any form of bribery by, or of, our employees, agents or consultants or any person or body acting on our behalf. Senior management is committed to implementing effective measures to prevent, monitor and eliminate bribery.
Live 2 Help Recruitment may also face criminal liability for unlawful actions taken by its employees or associated persons under the Bribery Act 2010. All employees and associated persons must familiarise themselves and comply with this policy, including any future updates.
2. Scope
This policy applies to all employees and officers of Live 2 Help Recruitment, and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, Live 2 Help Recruitment ("associated persons"), within the UK and overseas.
Every employee and associated person acting for, or on behalf of, Live 2 Help Recruitment is responsible for maintaining the highest standards of business conduct. Any breach of this policy is likely to be a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of Live 2 Help Recruitment. Agents, sub-contractors and suppliers must confirm in writing that they have received this policy and will follow it, and confirm each year that it has been followed in their dealings with and on behalf of Live 2 Help Recruitment.
3. Principles
We expect everyone working on our behalf to act with integrity and to high standards of ethical conduct. They are expected to:
- behave honestly and fairly;
- comply with all legal and regulatory requirements;
- conduct themselves in a manner that enhances the reputation of Live 2 Help Recruitment;
- treat others with respect; and
- safeguard the assets and property of Live 2 Help Recruitment.
They must not:
- use their authority or office for personal gain;
- recruit or promote employees other than on their ability;
- take unfair advantage of others through dishonest, unethical or illegal practices;
- misappropriate the assets or property of Live 2 Help Recruitment; or
- depart from this policy or any Live 2 Help Recruitment policy simply on the grounds of "commercial necessity".
4. Bribery Act 2010
Under the Bribery Act 2010, a bribe is a financial or other advantage offered or requested with the intention of inducing or rewarding improper performance of a function or activity, or with the knowledge or belief that accepting it would constitute improper performance. A relevant function or activity includes public, state or business activities, or any activity performed during a person's employment or on behalf of another company or individual, where the person is expected to act in good faith, impartially or in a position of trust.
A criminal offence will be committed if an employee or associated person acting for, or on behalf of, Live 2 Help Recruitment offers, promises, gives, requests, receives or agrees to receive a bribe, or offers, promises or gives a bribe to a foreign public official with the intention of influencing that official in the performance of their duties, and Live 2 Help Recruitment does not have adequate procedures in place to prevent bribery.
4.1 What is prohibited
Live 2 Help Recruitment prohibits employees and associated persons from offering, promising, giving, soliciting or accepting any bribe. A bribe might be cash, a gift or any other inducement to or from any person or company, whether a public or government official, an official of a state-controlled industry, a political party or a private person or company, and whether the individual is in the UK or overseas. This includes bribes intended to secure any commercial, contractual or regulatory advantage for Live 2 Help Recruitment, or any personal advantage for the individual or anyone connected with them. It also applies to indirect payments, gifts or contributions made through consultants, contractors, agents, sponsors, joint-venture partners, advisers, customers, suppliers or other third parties.
4.2 Record keeping
Employees and, where applicable, associated persons must make sure all company records relating to contracts or business activities, including invoices and payment transactions with clients, suppliers and public officials, are accurately maintained. Due diligence should be carried out before entering into any contract, arrangement or relationship with a potential supplier, agent, consultant or representative. Accurate, detailed and up-to-date records must be kept of all corporate hospitality, entertainment or gifts accepted or offered.
5. Corporate entertainment, gifts, hospitality and promotional expenditure
Live 2 Help Recruitment permits corporate entertainment, gifts, hospitality and promotional expenditure undertaken to establish or maintain good business relationships, to improve its image and reputation, or to present its services effectively, provided it is arranged in good faith and is not offered, promised or accepted to secure an advantage or to influence the impartiality of the recipient. We will authorise only reasonable, appropriate and proportionate expenditure, whether in the UK or overseas.
5.1 Charitable donations
Live 2 Help Recruitment considers that charitable giving can form part of its wider commitment to the community. Any charitable support is given openly, in good faith and never as an inducement.
6. Financial compliance and financial records
Our financial records must be complete and accurate so that they reflect the true state of the business and the true nature of all transactions. All books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect our transactions and must conform to applicable legal requirements and generally accepted accounting principles. It is prohibited to:
- make or approve any payment on the understanding that any part of it will be used for a purpose other than that recorded in our accounts;
- establish undisclosed funds or assets, make false or misleading entries in any accounting records, or destroy accounting records within statutory retention periods;
- use company funds or assets for any unlawful purpose; or
- knowingly make false or inaccurate statements to our accountants or auditors.
7. Confidentiality
Directors and staff must keep confidential any non-public information entrusted to them by Live 2 Help Recruitment, its clients, candidates or anyone else we do business with. Confidential information should never be disclosed outside the business unless authorised or legally required. This includes business and marketing plans, pricing, contract terms, client, candidate and supplier data, personal data under data protection law, and unpublished financial information. Confidential information must not be improperly collected, stored, distributed, lost or destroyed.
8. Conflicts of interest
Everyone working for Live 2 Help Recruitment must avoid situations which may give rise to a conflict of interest. A conflict of interest occurs when the private interests or actions of an individual may interfere with the interests of the business and make it difficult for them to work objectively and effectively. It may also arise where an individual or a member of their family receives improper benefits as a result of their position.
All potential conflicts of interest, including any direct or indirect interest in a competitor, contractor, supplier or consultancy (such as shareholdings or family relationships), must be disclosed to the Managing Director. All corporate hospitality and gifts received in the course of work should also be disclosed.
9. Responsibilities
Management: the Managing Director is accountable for compliance with this policy and for making sure adequate records are kept to demonstrate compliance. Our financial statements are prepared and reviewed by independent external accountants.
Employees: employees and associated persons must help uphold the principles in this policy by acting in a truthful, lawful and ethical manner in all their working practices.
10. Suspected breaches of this policy
We encourage an open door culture, so that any queries and concerns can be raised with management. Employees and associated persons should stay vigilant and report any concern as soon as possible to the Managing Director, including:
- any suspected or actual attempt at bribery;
- concerns that other employees or associated persons may be being bribed;
- concerns that other employees or associated persons may be bribing third parties, such as clients or officials; or
- any suspected theft or misappropriation of company property.
Anyone who reports suspected bribery or misconduct in good faith will be supported and will not be subjected to detrimental treatment as a result. Detrimental treatment of someone who has made a report will be treated as a disciplinary offence, as will any instruction to cover up wrongdoing. If told not to raise or pursue a concern, even by someone in authority, employees and associated persons should not agree to remain silent.
Live 2 Help Recruitment will fully investigate any alleged or suspected breach. Employees suspected of bribery or misconduct may be suspended while an investigation takes place, and proven allegations may result in a finding of gross misconduct and immediate dismissal. We may terminate the contracts of any associated persons found to have breached this policy and may report any matter to the relevant authorities, including the Serious Fraud Office and the police, and will assist them fully. Concerns can also be raised confidentially under our whistleblowing policy or by emailing office@live2helprecruitment.co.uk.