Anti-corruption and bribery policy

About this policy

It is the aim of 10 Degrees to conduct all business in an honest and ethical manner. In line with our core values of skilful, transparency, ethical, empathy and reliability, 10 Degrees is committed to ensuring the very highest standards of good business practices are maintained. This includes upholding all laws relevant to countering bribery and corruption in all jurisdictions in which we operate, including but not limited to, the UK Bribery Act 2010.

10 Degrees takes a zero-tolerance approach to bribery and corruption both within our own operations and in all our business dealings and relationships with our stakeholders, partners and suppliers.

This policy covers all employees and contractors working for 10 Degrees.

What is corruption?

Corruption is a broad term, but in a business context, it refers to the risk that directors, employees, partners or suppliers may not always act in an entirely honest or ethical manner.

This policy sets out clear guidance on how parties connected with 10 Degrees should conduct themselves, highlighting the expectation of 10 Degrees that any person connected with the business should behave with integrity and conduct business in a professional and fair manner.

What is bribery?

Bribery is one of the most common forms of corruption and therefore is dealt with explicitly within the broader context of this policy. A bribe is an offer to give or receive a financial or other reward to another person, in order that they perform their job, or an aspect of their work, improperly.

Offering or receiving a bribe is illegal and punishable under UK law and is applicable to bribes offered or accepted not only by directors and employees, but also by contractors or agents acting on our behalf.

What is the difference between a gift and a bribe?

Gifts should be appropriate and proportionate in terms of value, circumstance and the relationship with the individual or company offering/receiving it. This includes hospitality and entertainment.

If there is any indication at all that a gift is being offered in return for a favour, or as an incentive to enter a relationship or to influence a business decision, it is considered a bribe.

The policy

Risk assessment and due diligence

10 Degrees commits to regularly and comprehensively assess the nature and extent of internal and external risks relating to bribery to which we are exposed, including our business activities and opportunities across all of our operations; the markets in which we operate; our employees; as well as the business activities of our clients, suppliers, contractors, partners and agents.

Where appropriate, anti-bribery commitments will be written into contracts with third parties, and all suppliers should adhere to our supplier code of conduct which contains guidance for suppliers on anti-corruption and bribery.

Gifts and hospitality

All forms of hospitality, gifts and entertaining, whether given or received, must be reported to and approved by a senior manager.

The giving and receiving of gifts are allowable if the following requirements are met:

• It is not the intention to influence a third party or to obtain or retain business.
• It complies with local laws.
• It is given or received in the company’s name, not by you personally, and is given openly and not in secret.
• It does not include cash or cash equivalent and is appropriate, reasonable and justifiable for the market sector.

Your responsibilities

All employees must ensure that they read, understand and comply with this policy. It is the responsibility of individual employees to avoid any activity that might lead to, or suggest, a breach of this policy.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal.

How to raise a concern

You are encouraged to raise a concern about any issue or suspicion of misconduct or conflict of interest at the earliest possible stage.

We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

Please refer to our whistle blowing policy for further details.

How is this policy monitored and reviewed?

The risks we face as a business and the effectiveness of our procedures will change over time. This policy will therefore be reviewed on an annual basis, and we will continue to monitor the anti-corruption and anti-bribery steps we have taken. Any changes will be communicated to staff.