ANTI-BRIBERY & CORRUPTION POLICY

Introduction:

Bristol Venues is committed to the highest standards of ethical conduct and integrity in all of our business activities. We are fully compliant with the Bribery Act 2010 and take a zero tolerance approach to bribery and corruption. We expect all employees and individuals acting on our behalf to fulfil our Anti-Bribery and Corruption Policy and act with honesty and integrity. 

This policy applies to all employees, directors and officers, as well as individuals engaged to work with us or act on our behalf including temporary workers, consultants, contractors and third parties.

Any breach of this policy may constitute a serious disciplinary and criminal matter for the individual concerned and may cause serious damage to our company’s reputation. It may also lead to criminal liability for our business, based on any unlawful actions taken under the Bribery Act 2010.

It is the responsibility of all employees and associates of Bristol Venues to ensure that they do not offer or accept any form of bribery. If you are unsure about whether something may constitute bribery, please raise this with your manager and HR.

 

What is Bribery?

A bribe is a financial or other type of advantage that is offered or requested with the:

  • intention of inducing or rewarding improper performance of a function or activity and/or
  • knowledge or belief that accepting such a reward would constitute the improver performance of such a function or activity

A relevant function or activity includes public, state or business activities or any activity performed during someone’s employment or on behalf of another company or individual, where the person performing that activity is expected to perform it in good faith, impartially or in accordance with a position of trust.

A criminal offence will be committed if:

  • an employee, or person associated with our company, promises, gives, requests or agrees to receive bribes or
  • an employee, or person associated with our company, offers, promises or gives a bribe to a foreign public official with the intention of influencing them in the performance of their role (where local law doesn’t permit or require such influence) and
  • our company doesn’t have the defence that it has adequate procedures in place to prevent bribery by its employees or associated persons.

Our Commitment:

We will never accept, approve or request bribes of any kind, either directly or indirectly. We will also never offer or approve bribes of any kind. Bribes, which may be monetary or non-monetary, could be facilitated through:

  • financial payments
  • gifts, hospitality or entertainment (more details on these below)
  • discounts or loans
  • rebates
  • overpayments to business partners
  • use of assets 
  • political contributions
  • sponsorships or charitable contributions
  • employment

We remain alert to bribery and corruption and will report any acts or red flags should they occur.

Gifts and Hospitality:

We carefully manage giving and accepting gifts and hospitality and understand the risks of potential bribery and corruption associated with this. 

We don’t give or accept gifts and entertainment:

  • with the intention of gaining undue advantage
  • with the intention or potential of influencing decision makers
  • that are unreasonable or inappropriate
  • that could be regarded as a bribe in any way
  • in the form of cash, pre-paid cards or gift cards

Giving and accepting gifts and hospitality is still allowed in certain instances though. We give or accept gifts and hospitality that are:

  • in good faith
  • reasonable, appropriate and transparent
  • standard business courtesy 
  • promotional gifts of low value, such as branded stationery 

Working with clients and business partners:

We expect our clients and business partners to share our commitment to ethical business practices and take practical steps to screen and assess them before engaging in any business.

Raising a Concern:

Employees, workers and third parties must remain alert to bribery and corruption and let the CEO and HR know if they suspect that any bribery, corruption or other breach of this policy has taken place or may occur.

Any breach of this policy may constitute a serious disciplinary and criminal matter for the individual concerned and may cause serious damage to our company’s reputation. It may also lead to criminal liability for our business, based on any unlawful actions taken under the Bribery Act 2010.