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Anti-Bribery Policy

The Bribery Bill received Royal Assent on 8 April 2010 thereby becoming the Bribery Act 2010 (“The Act”) and came into force on 1 July 2011. Essentially, the Act makes it an offence to give or receive a bribe or to promise, offer or agree to receive a bribe. The maximum penalty for individuals will be 10 years’ imprisonment and/or a fine.

The maximum penalty for a company will be an unlimited fine. This document sets out the rules of Bearmach Ltd in relation to the above Bribery Act and corruption matters in the United Kingdom and worldwide.

Bearmach’s Code of Conduct

It is Bearmach Ltd’s policy to conduct business in an honest and ethical way, and without the use of corrupt practices or acts of bribery to obtain an unfair advantage.

Our organisation could be prosecuted under the UK Bribery Act if an associated person acting on our behalf conducts and active offence of bribery anywhere in the world.

Certification

The action and conduct of Bearmach officers, directors and employees (collectively Bearmach Ltd personnel), as well as others acting on Bearmach’s behalf are essential to maintaining these standards.

Bearmach’s personnel, including agents, consultants and contractors, as well as suppliers and any others acting on behalf of Bearmach’s international business must read, become familiar and comply with this Anti Bribery Policy and the Gifts and Entertainment Policy of which copies are available on request.

Compliance with Anti-Bribery Laws

It is Bearmach’s policy to comply with all laws, rules, and regulations governing anti bribery and corruption, in all countries where we operate. Bearmach has a zero-tolerance approach to acts of Bribery and corruption, this includes employees or anyone acting on our behalf.

Any breach of this policy will be regarded as a serious matter by the Company and is likely to result in disciplinary action. If the company is found to have taken part in the corruption or lacks adequate procedures to prevent bribery, it could face an unlimited fine and be excluded from tendering for Government contracts and face untold damage to its reputation.

What is bribery and corruption?

  • The payment or offer to pay bribes or anything of value such as rebates, kickback, or provisions of, or offer to provide gifts of value for improper purposes.
  • To receive or accept a financial or other advantage is also prohibited under the UK Bribery Act 2010.
  • To obtain or retain business or any other benefit (whether for Bearmach or any other party) is prohibited.
  • Such payments or gifts are also forbidden under the terms of this policy and may result in immediate dismissal for those involved in their payment or receipt.
  • Bribery is committed when an inducement or reward is provided, to gain any commercial, contractual, regulatory or personal advantage for another party.
  • No bribes of any sort may be paid or accepted from customers, suppliers, politicians, government advisors or representative's, private person or Company. It is not permitted to establish accounts or internal budgets for making facilitation payment or influencing transactions (slush funds).
  • Please note that facilitation payments should only be made in situations that his/her personal health and safety is at risk. If such payments are requested or made, appropriate procedures should be taken following the request and/or payment. For example, the incident should be reported to the appropriate person and if made, the transaction be accurately recorded in the books and records, including the actions taken to help mitigate future occurrences.

Application of the Policy

This policy applies to individual employees, agents, sponsors, intermediaries, consultants or any other people or bodies associated with Bearmach Ltd any of its subsidiaries and employees.

Gifts and Entertainment

Bearmach recognises that to refuse a gift in certain circumstances and/or countries would cause offence to our trading partners. The following test should be applied in all circumstances “is whether the gift or entertainment is reasonable and justifiable”.

  • What is the intention of the gift? Is the gift being offered for something in return (quid pro quo)?
  • This policy does not prohibit the following practices, providing they are customary in a particular market, or are appropriate and properly recorded. Please refer to our code of conduct and gifts policy for further information.
  • Normal and appropriate hospitality (given or received)
  • The giving of ceremonial gifts at a festival or at another special time, up to and not exceeding the value of 100 Euros.

Employee Responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees throughout the Group.

Any suspicion of bribery can be reported confidentially through normal channels of communication, which can be obtained through the Whistle Blowing policy, see information below.

Potential whistle blowers should be assured that they do not have to report their suspicions anonymously to maintain confidentiality.

Reporting Incidents of Bribery and Corruption

If you become aware that an activity or conduct has taken place, which you suspect is a bribe (or corrupt), you have a duty to report this. Any such incidents should be reported to your Supervisor/ Line Manager or, you should follow the Whistle Blowing contacts.

If an incident of bribery, corruption or wrong-doing is reported, we will act as soon as possible to evaluate the situation. Bearmach Ltd has clearly defined procedures for investigating fraud, misconduct and non-compliance issues and these will be followed in any investigation of this kind. If you have any questions about these procedures, please contact the Group Compliance Officer.

Whistle Blowing - Who to Contact

If you are concerned that a corrupt act of some kind is being considered or carried out, either within Bearmach Ltd, or any of our business partners or any of our competitors – you must report the issue/concern to Bearmach Ltd.

If an incident of bribery, corruption or wrong-doing is reported, we will act as soon as possible to evaluate the situation. Bearmach Ltd has clearly defined procedures for investigating fraud, misconduct and non-compliance issues and these will be followed in any investigation of this kind.

The Compliance Officer for the purposes of this policy is the Group Company Secretary - Mr Julian Burgess, who can be contacted by telephone 00 44 29 20 856 550 or by email at julianb@bearmach.com.

Internal and External Audits

Internal and external audits are carried out on a regular basis and as such Bearmach is required to keep financial records and must ensure that appropriate internal controls are in place to provide evidence and reasons for making payments to third parties.

Conclusion and Certification

It is the ultimate responsibility of the Main Board to routinely refresh and reinforce this policy and its underlying principles and guidelines. Local management is responsible for the establishment and on-going monitoring of compliance of this policy. Bearmach Ltd requires all relevant business parties are responsible for annual certification as to the receipt and understanding of this policy as part of our annual compliance training.

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