Our Anti Bribery & Corruption 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 in this company to ensure that no bribery occurs.
MPM is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. This policy outlines MPM’S position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. MPM will not tolerate any form of bribery by, or to, its employees, agents or consultants or any person or body acting on its behalf. Senior management is committed to implementing effective measures to prevent, monitor and eliminate bribery.
This policy applies to all employees of MPM, and to temporary workers, consultants, contractors, agents and subsidiaries acting for, or on behalf of, MPM (“associated persons”) within the UK and overseas. All are responsible for maintaining the highest standards of business conduct. Any breach of this policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of MPM.
MPM may also face criminal liability for unlawful actions taken by its employees or associated persons under the Bribery Act 2010.
What is prohibited?
MPM prohibits employees or associated persons from offering, promising, giving, soliciting or accepting any bribe. The bribe might be cash, a gift or other inducement to, or from, any person or organisation, whether a public or government official, official of a state-controlled industry, political party or a private person or organisation, regardless of whether the employee or associated person is situated in the UK or overseas.
This prohibition also applies to indirect contributions, payments or gifts made in any manner as an inducement or reward for improper performance, for example through consultants, contractors or sub-contractors, agents or sub-agents, sponsors or sub-sponsors, joint-venture partners, advisors, customers, suppliers or other third parties.
MPM prohibits the following practices:
1. Collusive practice – arrangement with two or more parties designed to achieve improper purpose or improper influence to the other party;
2. Theft – misappropriation of property belonging to another party;
3. Applying threats – any act by employees to create fear and for example by citing a senior management name or any persons of a higher authority within MPM or any other acts with the intent to prevent another employee from performing his duties;
MPM prohibits its employees or associated persons from making or accepting any facilitation payments. These are payments made to government officials for carrying out or speeding up routine procedures. They are more common overseas. Facilitation payments are distinct from an official, publicly available fast-track process.
Facilitation payments, or offers of such payments, will constitute a criminal offence by both the individual concerned and MPM under the Bribery Act 2010, even where such payments are made or requested overseas. Employees and associated persons are required to act with greater vigilance when dealing with government procedures overseas.
Corporate entertainment, gifts, hospitality and promotional expenditure
MPM permits corporate entertainment, gifts, hospitality and promotional expenditure that is undertaken:
• for the purpose of establishing or maintaining good business relationships;
• to improve the image and reputation of MPM; or
• to present MPM’s goods effectively;
• provided that it is:
• arranged in good faith; and
• not offered, promised or accepted to secure an advantage for MPM or any of its employees or associated persons or to influence the impartiality of the recipient.
MPM will authorise only reasonable, appropriate and proportionate entertainment and promotional expenditure.
This principle applies to employees and associated persons, whether based in the UK or overseas.
Any gifts, rewards or entertainment received or offered from clients, public officials, suppliers or other business contacts should be reported immediately to the Finance Director. In certain circumstances, it may not be appropriate to retain such gifts or be provided with the entertainment and employees and associated persons may be asked to return the gifts to the sender or refuse the entertainment, for example where there could be a real or perceived conflict of interest. As a general rule, small tokens of appreciation, such as flowers or a bottle of wine, may be retained by employees.
If an employee or associated person wishes to provide gifts to suppliers, clients or other business contacts, prior written approval from the Finance Director is required, together with details of the intended recipients, reasons for the gift and business objective. These will be authorised only in limited circumstances and will be subject to a cap of £100 per recipient.
Employees and, where applicable, associated persons must supply records and receipts, in accordance with MPM’s expenses policy.
Charitable and political donations
MPM makes regular donations to charity. These are managed and approved by the Finance Director and the Marketing Director. No employee should make donations to a charity without prior approval.
No donations should be made to charities, political parties or other companies with the intention of gaining a business advantage.
Reporting suspected bribery
If you are concerned that acts of bribery are occurring in MPM you should inform your manager in the first instance. If this course of action is inappropriate, you should inform the Finance Director.
Responsibilities of the Line Manager
If a line manager is concerned about any actions, they should contact the Finance Director immediately for advice.
Line managers are also responsible for ensuring that all employees reporting to them are aware of this policy, and fully understand the rules in relation to the acceptance of gifts and hospitality.
All Board members must fill in a “Conflict of Interest Questionnaire” annually.