Anti-Bribery and Anti-Corruption Policy
LYL Inventories Ltd – Anti-Bribery and Anti-Corruption Policy
Last Updated: 12th November 2024
Introduction
LYL Inventories Ltd (“we,” “us,” “our”) is committed to conducting its business with integrity, transparency, and accountability. We operate a zero-tolerance approach to bribery and corruption and ensure full compliance with the **UK Bribery Act 2010**. This policy provides guidelines to prevent bribery and corruption, outlining the responsibilities of all employees, contractors, and third-party representatives.
1. Purpose and Scope
The purpose of this policy is to:
- Prevent bribery and corruption in all business activities and transactions.
- Set clear guidelines for identifying and managing risks related to bribery and corruption.
- Define the responsibilities of employees, contractors, and third-party representatives in upholding ethical standards.
This policy applies to all LYL Inventories Ltd employees, contractors, suppliers, clients, and any other third-party representatives.
2. Definitions
- Bribery: Offering, giving, receiving, or soliciting something of value as a means of influencing the actions of an individual or organization.
- Corruption: Dishonest or fraudulent conduct by those in power, typically involving bribery.
- Facilitation Payments: Small payments made to expedite routine governmental actions. These are prohibited by this policy.
- Kickbacks: Payments returned to a person involved in a business arrangement as a reward for facilitating the transaction.
3. Policy Statement
LYL Inventories Ltd prohibits:
- Offering or accepting bribes, kickbacks, or facilitation payments.
- Making or receiving payments that seek to influence the outcome of a business decision.
- Providing gifts or entertainment with the intent of obtaining favorable treatment.
- Any corrupt activities or practices that could compromise the integrity of our business.
4. Responsibilities
4.1. Management
Management is responsible for:
- Leading by example and promoting an ethical, transparent business culture.
- Implementing anti-bribery training and awareness programs.
- Monitoring compliance with this policy and reviewing its effectiveness regularly.
4.2. Employees and Contractors
Employees and contractors must:
- Understand and adhere to this policy in all business dealings.
- Report any suspected bribery, corruption, or violations of this policy immediately.
- Avoid actions or relationships that could be perceived as corrupt or unethical.
4.3. Third-Party Representatives
Third-party representatives, including suppliers and agents, must comply with our anti-bribery standards. Contracts with third parties include clauses that require adherence to our policy.
5. Gifts, Hospitality, and Entertainment
We recognise that gifts and hospitality can build positive business relationships. However:
- Gifts and hospitality must be reasonable, infrequent, and transparent.
- All gifts or hospitality must be recorded in the **Gift and Hospitality Register**.
- Employees should avoid giving or accepting gifts valued over **£50** without management approval.
6. Reporting and Whistleblowing
Employees are encouraged to report any concerns about bribery or corruption. Reports can be made confidentially to the designated compliance officer. LYL Inventories Ltd guarantees protection for whistleblowers against retaliation.
7. Training and Awareness
All employees receive anti-bribery and anti-corruption training upon joining and regular refresher sessions to reinforce compliance and awareness.
8. Consequences of Non-Compliance
Any employee, contractor, or third party found to have engaged in bribery or corrupt practices will face disciplinary action, including possible termination of employment or contract and legal action if necessary.
9. Review of Policy
This policy is reviewed annually to ensure it remains effective and aligned with current legislation and best practices.
10. Contact Information
For questions or to report potential violations, please contact:
Compliance Officer
LYL Inventories Ltd
Email: compliance@lylinventories.com
Phone: 01277 283022