Anti-Bribery & Corruption Policy

1. Our position

We conduct business honestly and without bribery or corruption of any kind. We do not offer, give, request or accept a bribe, whether directly or through a third party, and whether or not the practice is common in a particular market.

The Bribery Act 2010 creates offences of bribing another person, being bribed, bribing a foreign public official, and the corporate offence of failing to prevent bribery by an associated person. This policy is part of the adequate procedures we maintain to prevent bribery being carried out on our behalf.

The policy applies to directors, employees, self-employed chauffeurs, agency staff, partner operators and any other person performing services for or on our behalf. Responsibility for it sits with the director responsible for compliance.

2. What counts as a bribe

A bribe is a financial or other advantage offered, given or received to induce or reward the improper performance of a function. It does not have to be cash, it does not have to succeed, and it does not have to be given by us directly to engage the corporate offence.

In our sector the realistic risks are specific: a payment to a concierge, driver, personal assistant or event organiser in exchange for directing bookings; a payment to a fleet or procurement contact in exchange for a contract award; a payment to expedite a licensing decision; or an inducement offered to a chauffeur to breach passenger confidentiality.

Commission and referral arrangements are not bribes where they are transparent, documented in a written agreement, at a commercial rate and disclosed to the client where the client's interest is affected. Undisclosed payments to an individual for steering business are treated as bribery.

3. Gifts and hospitality

• —Modest and occasional gifts and hospitality are permitted where they are proportionate, given openly and would not embarrass anyone if made public.
• —Cash and cash equivalents, including gift cards and vouchers, must never be offered or accepted.
• —Nothing may be offered or accepted during a tender, a contract negotiation or a licensing decision.
• —Gifts or hospitality above £50 require prior written approval from a director and are entered in the gifts and hospitality register.
• —Anything offered to a public official is refused politely unless a director has approved it in advance.
• —Passenger gratuities offered voluntarily to a chauffeur after a journey are not affected by this policy.

4. Facilitation payments and donations

Facilitation payments, meaning small unofficial payments made to secure or speed up a routine action, are bribes under UK law and are prohibited. If you are pressed for one, refuse, do not put yourself at risk, and report it to a director as soon as you safely can.

Charitable donations are made only to registered charities, only from company funds, and only with a director's approval. Donations are never made at the request of a client or prospective client as a condition of winning work.

We make no political donations of any kind, and no payment may be made on behalf of the business to a political party, campaign or candidate.

5. Record keeping

All accounts, invoices, expense claims and commercial agreements must reflect the true nature of the transaction. No off-book account, false invoice or vaguely described expense is permitted, and expenses relating to third parties must state who was present and why.

The gifts and hospitality register records what was given or received, by whom, to whom, the approximate value, the date and the business reason. It is reviewed by a director at least twice a year.

Records supporting these entries are retained in line with our Privacy Policy and our accounting obligations.

6. Third parties and partner operators

Bribery risk is highest where someone acts for us. Before engaging an agent, introducer or partner operator, we carry out proportionate due diligence on who they are, how they are paid and whether their remuneration is consistent with the work performed.

Written terms with third parties include an obligation to comply with the Bribery Act 2010 and with this policy, and a right for us to terminate immediately where there are reasonable grounds to believe bribery has occurred.

Commission is paid to a company or an individual for identified services at a documented rate. Payments are never made to a numbered account, to a third party nominated by the recipient, or in cash.

7. Raising a concern

Report any suspicion of bribery to a director. Where you would rather not raise it with the person you normally report to, a message sent through the WhatsApp client service desk on +44 7775 554848 and the contact page at executive-chauffeurs.uk/contact will be passed to a director on your behalf. Reports may be made confidentially, and we will discuss how far confidentiality can be preserved before taking any action.

Nobody who reports a genuine concern will suffer dismissal, loss of work, disciplinary action or any other detriment, even if the concern turns out to be mistaken. Qualifying disclosures are protected under the Public Interest Disclosure Act 1998.

Retaliation against someone who has raised a concern is itself a disciplinary matter and is treated as seriously as the conduct originally reported.

8. Breaches and review

A breach of this policy by an employee is gross misconduct and may result in dismissal. A breach by a self-employed chauffeur, partner operator or supplier is grounds for immediate termination of the engagement.

Where we conclude that an offence may have been committed, we will report the matter to the police or another appropriate authority and cooperate with any investigation. Individuals convicted of bribery face unlimited fines and imprisonment.

This policy is reviewed at least annually and whenever our commercial arrangements change materially. The date at the head of the page shows the current version.