The Group prohibits all forms of bribery, both giving and receiving, wherever it operates, both by its own employees and by any agent or business partner acting on its behalf.
A bribe is where someone is given a financial or other advantage to encourage that person to perform their function or activities improperly, or to reward that person for having already done so.
No employee should offer a bribe for any reason whatsoever, nor should a bribe be accepted by any employee.
Any employee who suspects that bribes are being paid or received in connection with any company transaction should report it immediately to a Company Director.
Bribery is a criminal offence in most countries in which the Group does business, and penalties can be severe.
Of particular note, the UK Bribery Act 2010 (the "Act"), in force from 1 July 2011, creates a new offence whereby a company will be liable for failing to implement adequate procedures to prevent bribery by "associated persons" of the company. This is irrespective of where the act of bribery takes place.
"Associated persons" include officers, employees, business partners, agents and, potentially, joint ventures in which a company has an interest.
Companies face unlimited fines and persons found to have connived or consented to bribery could be jailed for up to 10 years.
Convicted companies and individuals have to repay any gains made as a result of corruption.
Commercial reputation is severely damaged.
It is, therefore, vitally important that all of the Group's associated persons comply with all applicable anti-corruption legislation.
This anti-bribery policy has been adopted by the Group to ensure that its associated persons remain compliant with this legislation.
Failure to comply with this policy will be treated as Gross Misconduct.
To whom does the policy apply?
Every employee, director or officer of Severfield-Rowen Plc ("Severfield"), its subsidiaries and any joint venture company or partnership under the control of Severfield must follow this anti-bribery policy.
Contract staff must also follow the anti-bribery policy.
Contractors or consultants who are our agents or working on our behalf or in our name, through outsourcing of services, processes or any business activity, will be required to act consistently with the anti-bribery policy when acting on our behalf.
Independent contractors or consultants will be made aware of the anti-bribery policy as it applies to our staff in their dealings with them.