Anti Bribery Policy
Bribery is the accepting of gifts, money, hospitality or other favours in return for providing something of value to the briber. The purpose of this Policy is to set out the rules that must be followed by Vogal Group employees to ensure no bribery occurs.
Unacceptable Behaviour
The following behaviour is unacceptable and must not occur in this Company.
- Accepting or giving any financial or other reward from or to any person in return for providing some favour.
- Requesting a financial or other reward from any person in return for providing some favour.
- Offering any financial or other reward from any person or client in return for providing some favour.
Employees must not accept any gifts or hospitality during a tendering / procurement process under any circumstances. Where refusing a gift would cause major offence it should be accepted and donated to charity.
Acceptance of corporate hospitality must be transparent.
Normal business lunches and meals (with the exception of those offered as part of the tendering / procurement exercise) are exempt.
Offering Gifts or Hospitality
Vogal Group may wish to offer small gifts (e.g. token Christmas gifts) to customers, suppliers and other persons. If a gift is authorised by the Chairman or Managing Director, the employee is entitled to give it to the appropriate individuals. A record must be kept of all gifts.
Vogal Group may wish to run a hospitality event primarily aimed at thanking customers and suppliers for their custom and loyalty. Employees must not organise any additional hospitality event without seeking the authority from the Chairman or Managing Director.
The Vogal Group Financial Controller is responsible for keeping a record of all gifts and hospitality that are offered and / or received by employees. If the Financial Controller is concerned about any actions, they should contact the Chairman or Managing Director.
The employee responsible for HR in the company is to ensure that all employees are aware of this policy, and fully understand the rules in relation to the acceptance of gifts and hospitality.
Any employee who is concerned that he or she is being potentially bribed should report the matter to the Chairman, Managing Director, Financial Controller or a Director at the earliest opportunity.
Expenses
All expenses claims must be signed by the employee and submitted to the Financial Controller. All expenses will be check against receipts submitted. Any expenses that give rise for concern will be investigated.
Donations to Organisations
Donations are managed by the Chairman’s PA. No employee should make donations without the approval of the Chairman. No donation should be made to charities, political parties or other organisations with the intention a gaining a business advantage.
Disciplinary Action
Any employee found to have offered or accepted a bribe will face disciplinary action which could include dismissal for gross misconduct.
Raising Concern
If any employee is concerned that acts of bribery are occurring in the company they should inform the Chairman, Managing Director, Financial Controller or a Director.
Original Signed:
Rob Gault
Managing Director
Vogal Group Ltd.
​Date: 05th Jan 2025