A bribe is an inducement or reward offered, promised or provided in order to gain commercial, contractual, regulatory or personal advantage.

Perceived risks (not exhaustive) relate to inducements or rewards offered, received, promised or provided to:

• those responsible for buying to encourage purchases from given manufacturers or agents.
• those responsible for making decisions in relation to contracts for goods and services.
• those responsible for managing or awarding contracts subject to tender.
• any employee regarding the release of commercially sensitive information to a third party.
• the sales teams to secure the custom of a particular retailer or contractor.

Current controls and systems include:

• executive director and senior management team approval for credit facilities above pre-determined levels.
• pre-set guidance on the level of selling price discounts inclusive of compliance checks.
• regular commercial and financial review by senior executive management team members.
• executive director and senior management team approval in relation to budgetary control and approved suppliers.
• transparency and recorded disclosure of corporate hospitality, both given and received.

This policy does not prohibit normal and appropriate hospitality and the giving of gifts, however:

• it should not be given with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits.
• local laws must be complied with.
• it is given in the name of the operating business.
• it does not include cash.
• it is appropriate in type and value in the circumstances, and
• it is openly done with the relevant line manager informed of the receipt or of the giving.

The intention behind the gift should always be considered, is it reasonable and justifiable, and lavish hospitality or gifts must be avoided, both the giving of and receiving of.

The company reserves the right to forbid an employee from attending any event that is considered excessive, inappropriate or may give rise to a conflict of interest.

Gifts or hospitality should not be offered to, or accepted from, government officials or representatives without the prior approval of the Group Chief Executive.

It is not acceptable to:

• give, promise or offer, payment, gift or hospitality with the expectation that an inappropriate commercial business advantage will be received, or to reward an inappropriate commercial business advantage already given.
• give, promise or offer, payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure.
• threaten or retaliate against an employee who has refused to commit a bribery offence or who has raised concerns under this policy.
• engage in any activity that might lead to a breach of this policy.
• make or accept, facilitation payments or inducements of any kind.
• make contributions to political parties.

Employees must ensure that they read, understand and comply with this policy and each is responsible for the prevention, detection and reporting of bribery and other forms of corruption and avoiding any activity that might lead to, or suggest, a breach of this policy.

Employees must notify their manager or the Group Company Secretary (or through the whistle-blowing procedure) as soon as possible if they believe or suspect that a conflict or breach with this policy has occurred, or may occur in the future and are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. It is important that employees inform their manager or the Group Company Secretary as soon as possible of offers of a bribe by a third party, if asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. The contractual relationship with other workers may be terminated if they breach this policy.

In addition to current internal controls and systems regarding the accurate record keeping of transactions, the business should maintain a written record of any corporate hospitality together with a record of gifts accepted or offered with an estimated value of in excess of £250, with all hospitality or gifts received being declared to the relevant line manager. This record will be subject to managerial review.

Headlam is committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an employee believes that they have suffered any such treatment, they should inform their manager or the Group Company Secretary immediately.

The offences contained in the Bribery Act carry criminal penalties for individuals and organisations. For individuals, a maximum prison sentence of ten years and/or an unlimited fine can be imposed, whilst for companies, an unlimited fine can be imposed and Headlam businesses could be excluded from tendering for public contracts and face damage to their reputation.

The Bribery Act 2010, which became effective from July 2011, introduced new and more onerous requirements in respect of the ways in which businesses should conduct themselves.