Our Anti Bribery & Anti Corruption Policy.
Anti-Bribery & Anti-Corruption Policy
What Our Policy Covers
This anti-bribery policy is designed to establish the principles and responsibilities of Scientific Sanitation Solutions Ltd (referred to as "the Company") and its employees regarding our uncompromising stance against bribery and corruption. It serves as a source of guidance for all individuals associated with the Company, helping them recognise, prevent, and address issues related to bribery and corruption.
Scientific Sanitation Solutions Ltd is dedicated to conducting its business ethically and transparently, committed to implementing and enforcing measures to prevent bribery. We maintain a zero-tolerance approach towards bribery and corrupt activities. Our business operations, regardless of location, are conducted professionally, fairly, and with integrity.
The Company is committed to full compliance with anti-bribery and corruption laws in all jurisdictions where we operate. We are bound by the laws of the United Kingdom, including the Bribery Act 2010, both domestically and internationally.
Scientific Sanitation Solutions Ltd acknowledges that bribery and corruption are serious offenses, carrying penalties of up to ten years' imprisonment and substantial fines. Engaging in corrupt activities can result in an unlimited fine, exclusion from public contract bidding, and severe damage to our reputation. Therefore, we are resolute in our commitment to preventing bribery and corruption within our business operations, upholding our legal obligations with the utmost seriousness.
Who is Covered by the Policy
This anti-bribery policy is applicable to all individuals associated with Scientific Sanitation Solutions Ltd, including employees (regardless of employment type), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, third parties, and anyone connected to our subsidiaries, or their employees, irrespective of their location (within or outside of the UK). The policy extends to officers, trustees, board members, and committee members at all levels.
In this context, a third party refers to any individual or organisation that the Company encounters and collaborates with, including clients, customers, suppliers, distributors, business contacts, agents, advisers, government bodies, and public officials, as well as their representatives, politicians, and political parties.
All arrangements with third parties are subject to explicit contractual terms, including provisions that mandate compliance with minimum standards and procedures concerning anti-bribery and corruption.
Definition of Bribery
Bribery encompasses the act of offering, giving, promising, requesting, agreeing to, receiving, accepting, or soliciting something of value or advantage to influence an action or decision.
A bribe is any inducement, reward, or item of value offered to another individual to gain a commercial, contractual, regulatory, or personal advantage.
It's vital to understand that bribery is not confined to offering a bribe; accepting a bribe is equally unlawful.
Bribery is strictly forbidden. Employees must not engage in any form of bribery, whether directly, indirectly, or through a third party, such as an agent or distributor. Accepting bribes is equally prohibited. In situations where there's uncertainty about whether an action constitutes a bribe or a legitimate gift or act of hospitality, advice should be sought from the Company's compliance manager.
What is and What is NOT Acceptable
This section of the policy addresses four key areas:
1. Gifts and Hospitality
Scientific Sanitation Solutions Ltd accepts customary and appropriate gestures of hospitality and goodwill from or towards third parties, as long as such exchanges meet specific criteria, including:
- No intention to influence the recipient to obtain or reward business or a business advantage.
- No suggestion of an expected return favor.
- Compliance with local laws.
- Offered in the name of the Company, not in an individual's name.
- Exclusion of cash or cash equivalents.
- Appropriateness to the circumstances, timing, and reason for the gift.
- Transparent exchange, not a covert transaction.
- No selective gifting to influential individuals to gain direct influence.
- Value within predefined limits set by the Company's compliance manager.
- Avoiding gifts to government officials or politicians without prior approval from the compliance manager.
When declining a gift would be considered inappropriate, such as in cases where it may cause offense due to cultural or religious reasons, the gift may be accepted, provided that it is disclosed to the compliance manager.
Scientific Sanitation Solutions Ltd recognises that gift-giving practices vary across countries, regions, cultures, and religions, and therefore, the acceptability of gifts differs for each. As a best practice, both giving and receiving gifts should always be disclosed to the compliance manager. Gifts from suppliers must always be disclosed.
The intent behind offering or receiving a gift must always be scrutinised, and any uncertainty should lead to consultation with the compliance manager.
2. Facilitation Payments and Kickbacks
The Company strictly prohibits facilitation payments and kickbacks. Facilitation payments expedite or facilitate the performance of a public official for routine governmental actions. Kickbacks involve offering favors or advantages in exchange for a business benefit.
In situations where refusing a facilitation payment or kickback may jeopardize personal safety or that of family members, the following steps should be taken:
- Keep the payment to a minimum.
- Request a receipt, specifying the amount and reason for the payment.
- Create a record of the payment.
- Report the incident to your line