Anti-Bribery and Corruption Policy

1. Introduction

RaptorTech Recruitment Limited (“the Company”) is committed to conducting its recruitment business with the highest standards of integrity, honesty and ethical behaviour.

The Company has a zero-tolerance approach to bribery and corruption and will not tolerate bribery or any other improper payment, benefit or inducement, whether offered, promised, given, requested or accepted.

This policy sets out the Company’s approach to preventing bribery and corruption and is designed to support compliance with the Bribery Act 2010.

The Company expects all employees and anyone acting on its behalf to conduct business fairly, transparently and ethically. No individual should offer, request or accept anything that could improperly influence a business decision or create an obligation to provide preferential treatment.

Senior management is committed to preventing bribery and corruption and to maintaining appropriate and proportionate procedures to identify, prevent and address bribery risks.

2. Scope of this policy

This policy applies to all employees and officers of the Company and, where relevant, to anyone who provides services to or acts on behalf of the Company, including temporary workers, contractors, consultants, agents, intermediaries and other third parties (“associated persons”).

Everyone covered by this policy is responsible for complying with it and for raising any concerns about suspected bribery or corruption.

A breach of this policy may result in disciplinary action, termination of a contractual relationship and, where appropriate, referral to the relevant authorities. Bribery is also a criminal offence and may result in criminal liability for the individuals involved.

The Company may also be liable under the Bribery Act 2010 where a person associated with the Company bribes another person with the intention of obtaining or retaining business or a business advantage for the Company.

This policy applies to activities undertaken in the UK and, where applicable, overseas.

3. What is bribery?

Under the Bribery Act 2010, bribery generally involves offering, promising, giving, requesting or accepting a financial or other advantage with the intention of improperly influencing a person’s actions or decision-making.

Bribery can involve money, but it can also involve other benefits such as:

Gifts.
Hospitality or entertainment.
Discounts or preferential treatment.
Employment opportunities.
Personal services or favours.
Commissions or payments.
Inappropriate charitable or political contributions.
Any other benefit provided in exchange for improper treatment.

Bribery can occur in both the public and private sectors.

The Company prohibits both offering or giving a bribe and requesting, agreeing to receive or accepting a bribe.

4. Bribery in recruitment

Because of the nature of the Company’s business, particular care must be taken when dealing with clients, candidates, suppliers and other business contacts.

Employees and associated persons must not offer, promise, give, request or accept any financial or other advantage in connection with:

Winning or retaining a client or recruitment assignment.
Obtaining preferred supplier status or preferential access to vacancies.
Introducing or selecting a candidate.
Placing a candidate into a role.
Influencing a recruitment or hiring decision.
Allocating work or business opportunities.
Obtaining preferential treatment from a supplier.
Influencing the purchase of recruitment services, technology or other products.
Securing or retaining business for the Company.
Providing personal benefits to an employee, candidate, client, supplier or other business contact.

For example, employees must not accept a personal payment or benefit from a candidate in return for putting them forward for a vacancy, giving them preferential treatment or influencing a recruitment decision.

Similarly, employees must not provide a personal payment or benefit to a client, candidate or other third party in return for preferential treatment or business.

Any legitimate commission, fee, rebate or referral arrangement must be transparent, properly authorised and accurately recorded.

5. Gifts and hospitality

The Company recognises that reasonable and proportionate gifts and hospitality can form part of legitimate business relationships.

However, gifts or hospitality must never be offered, given or accepted with the intention of improperly influencing a business decision or obtaining an improper advantage.

Gifts and hospitality must be:

Reasonable and proportionate.
Provided for a legitimate business purpose.
Appropriate to the business relationship.
Given openly and transparently.
Permitted under the Company’s policies and procedures.
Unlikely to create an actual, potential or perceived obligation on the recipient.

Particular care must be taken where gifts or hospitality are offered or received:

During a tender or procurement process.
While a significant business decision is being considered.
In connection with the award or retention of a recruitment contract.
Where the recipient has influence over a purchasing or recruitment decision.
Where the frequency or value could reasonably be viewed as excessive.

Gifts or hospitality that could reasonably be perceived as an attempt to influence a business decision must not be offered or accepted.

Employees should seek approval from their line manager where there is any doubt about whether a proposed gift or hospitality is appropriate.

All material gifts and hospitality must be recorded in accordance with the Company’s internal procedures.

Small, occasional tokens of genuine appreciation may be acceptable where they are reasonable and proportionate. Examples might include modest promotional items or an occasional meal of reasonable value.

Cash or cash equivalents must never be offered or accepted as a gift.

6. Conflicts of interest

Employees and associated persons must avoid situations where personal interests could conflict, or appear to conflict, with the interests of the Company.

Any actual, potential or perceived conflict of interest must be disclosed promptly to the appropriate manager.

Examples may include:

Having a personal or financial interest in a supplier or client.
Having a close personal relationship with a candidate where the employee is involved in the recruitment decision.
Receiving a personal benefit from a business contact.
Recommending a supplier or service provider where the employee has a personal interest.
Directing business to an organisation in which the employee or someone connected to them has an interest.

The Company will consider the circumstances and determine what action, if any, is appropriate.

7. Facilitation payments

The Company prohibits facilitation payments.

A facilitation payment is generally a small unofficial payment made to a public official to secure or speed up a routine governmental action to which a person is otherwise entitled.

Employees and associated persons must not make, offer, request or accept facilitation payments, regardless of where the payment is requested.

This does not prevent the use of a legitimate, publicly available fast-track or priority service where a formal fee is published, the service is available to others on the same terms and the payment is properly documented.

If an employee or associated person is asked to make a payment that they believe may be a facilitation payment or otherwise improper payment, they should refuse where it is safe to do so and report the matter to their line manager or the person responsible for this policy.

8. Payments, expenses and financial records

The Company requires all payments and expenses to be properly authorised, accurately recorded and supported by appropriate documentation.

Employees and associated persons must not:

Create or maintain false, misleading or incomplete records.
Disguise the nature or purpose of a payment.
Make payments into personal accounts where this is not justified and authorised.
Make unofficial cash payments.
Submit false or misleading expense claims.

Any commission, referral fee, discount, rebate or other payment to a third party must have a legitimate business purpose, be appropriately authorised and be accurately recorded.

The Company will maintain appropriate financial controls designed to prevent and detect improper payments.

9. Third parties and associated persons

The Company recognises that bribery risks may arise through third parties acting on its behalf.

Where proportionate to the circumstances and level of risk, the Company will undertake appropriate due diligence before entering relationships with relevant third parties, including agents, consultants, contractors, intermediaries and other associated persons.

The Company may require relevant third parties to:

Comply with this policy or equivalent anti-bribery requirements.
Provide appropriate information about their ownership, activities and relationships.
Disclose potential conflicts of interest.
Provide information or assistance where concerns regarding bribery arise.

The level of due diligence and controls applied will be proportionate to the nature and level of risk.

10. Charitable and political donations

The Company does not permit charitable or political donations to be used as a means of obtaining or retaining business or securing an improper business advantage.

Any charitable donation made by or on behalf of the Company must have a legitimate purpose, be appropriately authorised and be accurately recorded.

The Company will not make political donations where doing so could create an actual, potential or perceived conflict with its business interests or be viewed as an attempt to obtain an improper advantage.

Employees and associated persons must not make charitable or political donations on behalf of the Company without appropriate authorisation.

11. Working overseas

The Company may occasionally conduct business with organisations or individuals outside the UK.

The principles contained in this policy apply regardless of where business is conducted.

Employees and associated persons should exercise particular care where local business practices differ from those in the UK. The fact that a payment, gift or other practice may be customary in another country does not make it acceptable under this policy.

Where an employee or associated person is unsure whether a proposed payment, gift, hospitality or business arrangement is appropriate, they should seek advice before proceeding.

12. Reporting concerns

The Company relies on employees and associated persons to help prevent and identify bribery and corruption.

Any employee or associated person who becomes aware of, suspects or is concerned about any of the following must report the concern as soon as reasonably practicable to their line manager or the person responsible for this policy:

An actual or attempted bribe.
A request for an improper payment or benefit.
A gift or hospitality arrangement that appears inappropriate.
Falsification or concealment of financial records.
An undisclosed conflict of interest.
Improper activity by an employee or associated person.
Pressure to breach this policy.

Concerns may also be raised through the Company’s whistleblowing procedure where appropriate.

Clients, candidates, suppliers and other external parties can raise concerns using the following contact details:

Reporting contact: Simon Arnold
Email: simon@raptortechrecruitment.co.uk

Reports will be treated sensitively and investigated appropriately.

The Company will not tolerate retaliation or detrimental treatment against anyone who raises a genuine concern in good faith. Any attempt to discourage, threaten or penalise someone for raising a legitimate concern may itself constitute misconduct.

An instruction to conceal wrongdoing or to ignore a suspected breach of this policy must not be followed and should be reported.

13. What to do if you are unsure

Bribery can sometimes involve situations where the correct course of action is not immediately obvious.

Employees and associated persons should not assume that an arrangement is acceptable simply because:

The payment or gift is small.
It is common practice in the industry.
Another organisation does it.
The recipient has requested it.
It is described as a “commission”, “facilitation fee” or “business development expense”.
The activity takes place outside the UK.

Where there is any doubt, employees and associated persons should seek guidance from their line manager or the person responsible for this policy before proceeding.

14. Breaches of this policy

The Company will investigate suspected breaches of this policy.

Where an employee is found to have breached the policy, the Company may take disciplinary action. Depending on the circumstances, a breach may constitute gross misconduct and could result in dismissal.

The Company may terminate the relationship with an associated person who breaches this policy or who exposes the Company to an unacceptable bribery or corruption risk.

The Company may also report suspected criminal conduct to the appropriate authorities and will cooperate with any resulting investigation.

Nothing in this policy prevents the Company from taking legal action where appropriate.

15. Training and communication

The Company will communicate this policy to employees and relevant associated persons.

Appropriate anti-bribery information or training will be provided where the individual’s role or activities create a relevant bribery risk.

Training and communication will be proportionate to the size and nature of the business and the risks identified.

Employees and associated persons are expected to familiarise themselves with this policy and comply with any related procedures.

16. Monitoring and review

The Company will take a proportionate approach to monitoring bribery and corruption risks.

This may include reviewing:

Expenses and payments.
Gifts and hospitality.
Third-party relationships.
Conflicts of interest.
Relevant contracts and arrangements.
Reports or concerns raised under this policy.

The Company will periodically assess whether its anti-bribery procedures remain appropriate and effective and will make changes where necessary.

This policy will be reviewed at least annually, or sooner where there are significant changes to the Company’s business, legal requirements or identified risks.

17. Responsibilities

The Directors and senior management are responsible for demonstrating the Company’s commitment to preventing bribery and corruption.

Managers are responsible for supporting compliance with this policy within their areas of responsibility and for escalating concerns appropriately.

All employees and associated persons are responsible for:

Reading and complying with this policy.
Acting honestly and ethically.
Avoiding bribery and improper conduct.
Maintaining accurate records.
Declaring relevant conflicts of interest.
Reporting concerns promptly.

18. Policy status

This policy does not form part of any employee’s contract of employment and the Company reserves the right to amend or update it from time to time.