Anti-Bribery Policy

Introduction:

  • Bribery is a criminal offence. 
  • We do not, and will not, pay bribes or offer improper inducements to anyone for any purpose, nor do we or will we, accept bribes or improper inducements. 
  • To use a third party as a conduit to channel bribes to others is a criminal offence. 
  • We do not, and will not, engage indirectly in or otherwise encourage bribery
  • We are committed to the prevention, deterrence and detection of bribery. We have zero-tolerance towards bribery. We aim to maintain anti-bribery compliance “business as usual”, rather than as a one-off exercise.

Definition:

Bribery is an inducement or reward offered, promised or provided to gain personal, commercial, and regulatory or contractual advantage. It is unacceptable to:

  • Give, promise to give, or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.
  • Give, promise to give, or offer a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure.
  • Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them.
  • Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return.
  • Retaliate against or threaten a person who has refused to commit a bribery offence or who has raised concerns under this Policy.
  • Engage in activity in breach of this Policy.

Objective of this Policy:

This Policy provides a coherent and consistent framework to enable Tissue for Research (the Company) employees to understand and implement arrangements enabling compliance. In conjunction with related policies and key documents it will also enable employees to identify and effectively report a potential breach. We require that all staff, including those permanently employed, temporary agency staff and contractors:

  • Act honestly and with integrity at all times and to safeguard the organisation’s resources for which they are responsible
  • Comply with the spirit, as well as the letter, of the laws and regulations of all jurisdictions in which Tissue For Research operates, in respect of the lawful and responsible conduct of activities.

Scope of this Policy:

  • This Policy applies to all the Company’s activities. 
  • For partners, joint ventures and suppliers, we will seek to promote the adoption of policies consistent with the principles set out in this Policy.
  • Within the Company, the responsibility to control the risk of bribery occurring resides in all aspects of the business and all corporate functions.
  • This Policy covers all and any employee, staff, those permanently employed, temporary agency staff, contractors, agents, Directors, volunteers and consultants.

Tissue for Research’s Commitment to Action:

The Company commits to:

  • Setting out a clear anti-bribery Policy and keeping it up to date
  • Making all employees aware of their responsibilities to adhere strictly to this Policy at all times
  • Informing employees so that they can recognise and avoid the use of bribery by themselves and others
  • Encouraging its employees to be vigilant and to report any suspicions of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately
  • Rigorously investigating instances of alleged bribery and assisting police and other appropriate authorities in any resultant prosecution
  • Taking firm and vigorous action against any individual(s) involved in bribery
  • Provide information to all employees to report breaches and suspected breaches of this Policy
  • Include appropriate clauses in contracts to prevent bribery.

Facilitation Payments:

Facilitation payments are not tolerated and are illegal. Facilitation payments are unofficial payments made to public officials in order to secure or expedite actions.

Gifts & Hospitality:

Sample tokens of modest value bearing the name or insignia of the organisation giving them (for example, pens, diaries or calendars or similar gifts) whether given personally, or received in the post, may be retained unless they could be regarded as an inducement or reward. You should refuse the offer or invitation (or return the gift) unless your Director has advised you that it may be accepted or retained.

Corporate hospitality should be proportionate and not be regarded as an inducement.