Anti-bribery and corruption policy

Appoint Group Limited, company number 16912796, registered in England and Wales. Registered office: 124-128 City Road, London EC1V 2NX. Questions about this policy: hello@getappoint.co.uk.

1. Our position

We do not offer, promise, give, request or accept bribes, and we do not allow anyone to do so on our behalf. This applies wherever we do business and whoever we are dealing with. There is no exception for local custom, for small amounts or for a deal we would otherwise lose.

We conduct our business honestly, and we expect the same of the people and organisations we work with.

2. Who this policy applies to

This policy applies to the directors, employees and workers of Appoint Group Limited, and to every contractor, consultant, agent, introducer and other person who performs services for us or on our behalf. We expect our suppliers, resellers and business partners to meet the same standard, and our contracts with them will say so.

3. The law

The Bribery Act 2010 makes it an offence to:

• bribe another person (section 1);
• request, agree to receive or accept a bribe (section 2); and
• bribe a foreign public official to obtain or retain business or a business advantage (section 6).

Under section 7 of the Act, a commercial organisation commits an offence if a person associated with it bribes someone intending to obtain or retain business or a business advantage for the organisation. The organisation has a defence only if it can prove that it had adequate procedures in place to prevent bribery. This policy, and the way we apply it, are part of those procedures.

Under section 11 of the Act, an individual convicted on indictment faces imprisonment for up to 10 years, a fine, or both. An organisation convicted under section 7 faces a fine. A conviction would also end our ability to work with many of the customers we exist to serve.

4. What a bribe is

A bribe is a financial or other advantage that is offered, promised, given, requested or accepted in order to induce or reward someone to perform a function or activity improperly, or where accepting it would itself be improper. It does not have to be money. Gifts, hospitality, travel, employment or work experience for a relative, a donation to a favoured cause, a discount, a loan or any other favour can be a bribe if it is given for the wrong reason. The offence is committed whether the advantage is given directly or through someone else, and whether or not the bribe achieves its purpose.

5. Gifts and hospitality

Reasonable, proportionate gifts and hospitality are a normal part of business, and this policy does not prohibit them. They are permitted only when all of the following are true:

• they are modest in value, infrequent, and given or received openly;
• they are a normal courtesy in the circumstances, such as a working meal or a branded item of low value;
• they are not offered or accepted while a decision in which we or the other party have an interest is pending, such as a tender, a contract renewal, a regulatory matter or a dispute;
• they are not cash or a cash equivalent, such as a voucher or a prepaid card; and
• they could not reasonably be seen as an attempt to influence a decision.

Any gift or hospitality worth more than a token amount, whether offered by us or to us, must be approved in advance by a director and recorded in the company's gifts and hospitality register. Anything offered to or received from a public official, of any country, must be approved in advance by a director regardless of its value.

If you are offered something that this policy does not allow, decline it politely, explain that our policy does not permit it, and tell a director.

6. Facilitation payments and kickbacks

We do not make facilitation payments: small, unofficial payments to speed up a routine action by an official, such as issuing a permit or clearing a customs check. We do not pay or accept kickbacks: payments made in return for a business favour or advantage.

If someone demands a payment of this kind, refuse it and report the demand to a director. If you believe that refusing would put your safety or liberty at risk, you may pay, but you must report the payment to a director as soon as you safely can, and we will record it.

7. Political and charitable contributions

Appoint Group Limited does not make donations to political parties, candidates or campaigns, in the United Kingdom or anywhere else.

Charitable donations and sponsorship are permitted only with the prior approval of a director, must be recorded, and must never be made to win business, to influence a decision or at the request of a customer, official or other person with whom we are doing business.

8. Keeping accurate records

We keep accurate and complete financial records so that every payment can be accounted for. No account, fund or transaction is kept off the books. Every expense claim states what the money was spent on and who was involved, and no claim may be submitted for a payment that this policy does not allow.

9. Third parties who act for us

Before we engage an agent, introducer, reseller or other third party to act on our behalf, we will carry out checks that are proportionate to the risk, including who they are, how they are paid and where they operate. Our contract with them will require compliance with the Bribery Act 2010 and with this policy, and will allow us to end the arrangement if it is broken. Payments to third parties must be for services actually provided, at a rate that is reasonable for those services, and must be properly documented.

10. Raising a concern

If you are asked to pay or accept a bribe, or you suspect that bribery or corruption is connected with our business, tell us as soon as possible at hello@getappoint.co.uk, or speak to a director. You can raise a concern without giving your name, although that may limit what we are able to do.

We will look into every concern raised in good faith, and nobody who raises one will suffer any detriment for doing so, even if the concern turns out to be mistaken. Workers who make a protected disclosure have the protection of Part IVA of the Employment Rights Act 1996.

11. Breaches

A breach of this policy is a serious matter. For an employee or worker it will be treated as gross misconduct and may lead to dismissal. For a contractor, agent or supplier it may lead to the immediate end of the relationship. Where we believe a crime may have been committed, we will report it to the police, the Serious Fraud Office or another appropriate authority.

12. Responsibility and review

The board of directors of Appoint Group Limited is responsible for this policy, for making sure that everyone it applies to knows and understands it, and for the company's compliance with it.

We will review this policy at least once a year, and sooner if our business changes in a way that affects it. The date at the top of this page shows when it was last reviewed.