Issued pursuant to the UK Bribery Act 2010 and applicable international standards.
1. Purpose and Scope
GEN (Global Enterprise Networks) is committed to conducting all of its business with integrity, transparency and in full compliance with the UK Bribery Act 2010 and all other anti‑bribery and anti‑corruption laws in the jurisdictions in which we operate. This Policy sets out our zero‑tolerance approach to bribery and corruption and provides practical rules for everyone who works for or on behalf of GEN.
This Policy applies to all employees, officers, directors, workers, contractors, agency staff, interns, consultants, agents, resellers, channel partners, intermediaries, introducers and any other third parties acting on GEN’s behalf (together, “Associated Persons”) globally.
2. Policy Statement
GEN has zero tolerance for bribery and corruption. Offering, giving, requesting, agreeing to receive or accepting a bribe is strictly prohibited, whether directly or indirectly, and regardless of local custom or practice. Facilitation payments are prohibited.
3. Definitions
- Bribe: An inducement or reward offered, promised, provided, requested or accepted to improperly influence a person’s actions or decisions.
- Anything of value: Cash, cash equivalents (e.g. gift cards), gifts, hospitality, travel, accommodation, meals, services, discounts, loans, favours, job offers or internships, donations, sponsorships, political contributions, or confidential information.
- Public official: Any officer or employee of a government, agency, state‑owned or state‑controlled enterprise, political party, candidate for political office, or a person acting in an official capacity.
- Facilitation payment: A small, unofficial payment to secure or speed up a routine action. These are prohibited, even where lawful locally.
4. Prohibited Conduct
- Offering, giving, requesting, agreeing to receive or accepting a bribe.
- Making, offering or accepting facilitation payments.
- Providing or accepting gifts, hospitality or expenses that are excessive, lavish, frequent, or intended to influence a business decision.
- Offering or providing anything of value to a public official to improperly influence them.
- Creating or using false, misleading or inaccurate records or invoices.
- Using third parties to channel improper payments or benefits.
5. Gifts, Hospitality and Expenses
Gifts and hospitality must be modest, infrequent, proportionate, for a legitimate business purpose, and never intended to obtain or retain business or a business advantage. Cash or cash equivalents are never permitted.
Thresholds and approvals (GBP):
- Up to £50: permitted without prior approval if reasonable and not during tenders; record in the Gifts & Hospitality Register.
- £50–£250: requires prior line‑manager approval and entry in the Register.
- Above £250: requires written pre‑approval from Compliance and entry in the Register.
- Public officials: any value requires written pre‑approval from Compliance and may only be provided where lawful and appropriate.
Business expenses (e.g. travel to a site visit) must be reasonable, properly authorised in advance where required, supported by receipts, and recorded accurately.
6. Charitable Donations and Sponsorships
GEN supports legitimate charitable giving and sponsorships. Such contributions must never be used as a subterfuge for bribery, must be transparent, and must be approved per the Delegation of Authority. Political donations by or on behalf of GEN are prohibited.
7. Conflicts of Interest
All Associated Persons must avoid situations where personal interests conflict, or may appear to conflict, with GEN’s interests. Conflicts must be disclosed promptly to your line manager and Compliance and managed as directed.
8. Third‑Party Due Diligence and Contracting
GEN applies risk‑based due diligence to intermediaries, agents, resellers, introducers, consultants, and high‑risk suppliers prior to engagement and periodically thereafter.
Due diligence typically includes:
- Verification of identity, beneficial ownership and corporate structure.
- Screening for sanctions, adverse media and corruption‑related enforcement.
- Assessment of proposed scope, compensation and justification for using a third party.
- Confirmation of relevant qualifications and references.
Contracts with third parties must include appropriate anti‑bribery warranties, audit and termination rights, and require compliance with this Policy and applicable law. Compensation must be proportionate to legitimate services actually rendered and paid via normal banking channels against valid invoices.
9. Interaction with Public Officials
Extra care is required when dealing with public officials. Any engagement involving public officials (including gifts, hospitality, travel, sponsorships or charitable donations connected to them) requires written pre‑approval from Compliance.
10. Books, Records and Financial Controls
All transactions must be recorded accurately and completely in GEN’s books and records. Off‑book accounts, falsified records and incomplete descriptions are prohibited. The Finance team maintains appropriate internal controls to detect and prevent improper payments.
A central Gifts & Hospitality Register is maintained by Compliance. Entries must be made within five (5) working days of giving or receiving any gift or hospitality.
11. Training and Communication
All employees complete mandatory anti‑bribery training on induction and at least annually thereafter. Personnel in higher‑risk roles (e.g. sales, procurement, field services) receive enhanced training. Completion is tracked and reported to senior management.
12. Reporting Concerns and Whistleblowing
If you are offered a bribe, asked to make one, suspect any breach of this Policy, or encounter a demand for a facilitation payment, you must report it immediately. Reports can be made to your line manager, to Compliance at compliance@gen.uk, or via our contact page at gen.uk/contact.php.
GEN prohibits retaliation against any person who raises a concern in good faith. Concerns may be raised anonymously where permitted by law.
13. Facilitation Payments and Demands under Duress
Facilitation payments are prohibited. If you reasonably believe your personal safety is at risk, you may make a payment under duress to secure immediate safety. You must report any such incident to Compliance as soon as practicable and obtain a receipt where possible so that it can be recorded properly.
14. Roles and Responsibilities
- Board of Directors: Sets the tone from the top and approves this Policy.
- Executive Leadership: Ensures adequate resources and oversight.
- Compliance (Policy Owner): Maintains the programme, provides guidance, keeps the Register and investigates concerns.
- Managers: Lead by example, ensure team awareness and approval processes are followed.
- All Associated Persons: Read, understand and comply with this Policy; complete training; raise concerns promptly.
15. Risk Assessment, Monitoring and KPIs
GEN conducts periodic bribery and corruption risk assessments proportionate to our size and profile. The effectiveness of our programme is monitored through internal reviews and independent audits where appropriate.
Indicative KPIs include:
- 100% of employees completing annual anti‑bribery training.
- 100% of higher‑risk third parties subject to proportionate due diligence.
- Quarterly review of the Gifts & Hospitality Register by Compliance.
- Timely investigation and closure of reported concerns.
16. Disciplinary Action and Consequences
Breaches of this Policy may result in disciplinary action up to and including summary dismissal. GEN may terminate relationships with third parties who violate this Policy and will report matters to law enforcement where appropriate. Individuals may face criminal penalties, including imprisonment and fines.
17. Record Retention
Records related to this Policy (including due diligence files, approvals, registers and training records) are retained for a minimum of seven (7) years, or longer where required by law or contract.
18. Adequate Procedures (UK Bribery Act Principles)
- Proportionate procedures.
- Top‑level commitment.
- Risk assessment.
- Due diligence.
- Communication (including training).
- Monitoring and review.
19. Review and Approval
This Policy is approved by the Board and will be reviewed at least annually, or sooner in response to material changes in law, risk or business operations.