Anti-Bribery and Corruption Policy

1. Scope and commitment

This policy applies to Featherstone Safety Ltd, registered in England and Wales under company number 17410006, and to everyone who works for or on behalf of the company in any capacity — the director, any employee, and every contractor, subcontractor, associate or agent.

We have a zero-tolerance approach to bribery and corruption. We will not offer, promise, give, request, agree to receive or accept a bribe, whether directly or through a third party, and whether in the United Kingdom or anywhere else. We are committed to acting professionally, fairly and with integrity in all our business dealings.

Bribery is a criminal offence under the Bribery Act 2010. An individual convicted of bribery can face an unlimited fine and up to ten years’ imprisonment. A commercial organisation can commit a separate offence under section 7 of failing to prevent bribery by a person associated with it, for which the only defence is having adequate procedures in place. This policy is part of those procedures.

2. Top-level commitment

This policy is owned, approved and enforced by the director of Featherstone Safety Ltd. The director is personally responsible for ensuring it is followed, for investigating any concern raised, and for reviewing the policy. There is no commercial target, deadline or client relationship that justifies a departure from it, and no one will be penalised for refusing to pay or accept a bribe, even if that costs the company business.

3. Risk assessment

We assess our bribery and corruption risk at least annually, and whenever the business, its markets or its supply chain change materially. The assessment considers the sectors and clients we work with, the countries we operate in, the way we win work, our use of subcontractors and referral arrangements, and the reputational risk our conduct could create for our customers.

Our current assessed position is:

• We operate only in the United Kingdom. We do not trade in, or with, higher-risk jurisdictions, and we have no dealings with foreign public officials.
• We do not use agents, intermediaries or introducers to win public sector work.
• We hold no procurement decision-making role for any customer, so we are not in a position to be offered a bribe to influence one.
• Residual risk sits mainly in two places: hospitality around business development, and referral or commission arrangements with partners. Both are controlled under sections 5 and 6 below.

We recognise that our conduct carries reputational risk for our customers as well as for ourselves, and we treat that as part of the risk we are managing, not as a separate matter.

4. Controls

• No bribes, in either direction. No payment, gift, hospitality, favour or other advantage may be offered, given, requested or accepted where it is intended to induce or reward the improper performance of a function, or where it might reasonably be seen that way.
• Facilitation payments are prohibited. See section 6.
• Gifts and hospitality are controlled and recorded. See section 5.
• Conflicts of interest must be declared and managed. See section 7.
• Transparent records. All payments made and received are recorded in the company’s accounting records with an accurate description. No off-book account, false invoice or misleading description may be used.
• Due diligence on third parties. Before engaging a subcontractor, agent, partner or referral source, we consider bribery risk as part of selection, and our engagement terms require compliance with the Bribery Act 2010.
• Political donations. We make no political donations of any kind.
• Charitable donations are made only to registered charities and never as an inducement, never at the request of a customer decision-maker, and never in place of a payment that could not properly be made.

5. Gifts and hospitality

Modest, reasonable and proportionate business hospitality given or received openly, to build or maintain a normal working relationship, is acceptable. Anything that could reasonably be seen as intended to influence a decision is not.

A gift or hospitality is acceptable only if all of the following apply. It must:

• not be given or received with the intention of influencing a decision or obtaining an improper advantage;
• not be cash or a cash equivalent, such as a voucher or gift card;
• be given openly, in the company’s name, and not to a person’s home address or private account;
• be reasonable and proportionate in the circumstances, and not lavish;
• comply with the recipient organisation’s own rules — public sector bodies, and NHS organisations in particular, often have stricter rules or an outright prohibition, and their rules take precedence over ours; and
• be capable of being disclosed publicly without embarrassment.

Anything with a value above £50, and anything at all offered or received during a live tender, bid or contract negotiation, must be approved by the director in advance and recorded in the gifts and hospitality register. The register is reviewed as part of the annual policy review and is available to a customer on request.

6. Facilitation payments and kickbacks

A facilitation payment is a small unofficial payment made to secure or speed up a routine action that the payer is already entitled to. Unlike some other jurisdictions, the Bribery Act 2010 provides no exemption for them: they are bribes.

We do not make or accept facilitation payments or kickbacks of any kind. If one is requested, the request must be refused and reported to the director immediately, and recorded. If a payment is ever made because a person reasonably believed their life or safety was at immediate risk, it must be reported at the first safe opportunity and recorded accurately; the company will not treat that as a disciplinary matter.

7. Conflicts of interest

A conflict of interest arises where a personal, financial or other interest could improperly influence, or appear to influence, a business decision. Anyone working for or on behalf of the company must declare any actual or potential conflict to the director as soon as they become aware of it.

Declared conflicts are recorded in a conflicts of interest register with the date, the nature of the conflict and the action taken. Where a conflict is relevant to a customer, a prospective customer or another affected party, we disclose it to them, and we do so before the decision it could affect is taken. Depending on the circumstances, we will manage a conflict by disclosure, by removing the affected person from the decision, or by declining the work.

We also disclose any interest that a reasonable customer would want to know about when we recommend a product or service, including any commission, referral fee or partner arrangement from which we would benefit.

8. Communication and training

Everyone working for or on behalf of the company is given this policy, and is required to confirm they have read and will comply with it, at the point they are engaged and at least annually afterwards. Where the company engages an employee, this forms part of their induction. Contractors and subcontractors receive it before they begin work, and our engagement terms require compliance with it.

The policy is published here so that customers, suppliers and prospective partners can see our position without having to ask.

9. Monitoring, review and reporting a concern

The director reviews this policy, the gifts and hospitality register and the conflicts of interest register at least annually, and after any reported concern. The review checks that the controls are being applied in practice, not just documented, and the outcome is recorded.

If you have a concern about bribery or corruption involving this company — whether you work with us, buy from us, supply us, or simply became aware of something — please report it to thomas@featherstonesafetyhub.co.uk. Concerns are treated confidentially so far as is possible, are investigated, and the outcome is recorded. No one will suffer any detriment for raising a concern honestly and in good faith, and any attempt to cause them detriment would itself be a serious matter.

Concerns can also be raised outside the company. Protect, the whistleblowing charity, offers free confidential advice on 020 3117 2520. Serious fraud or corruption can be reported to Action Fraud on 0300 123 2040.

10. Status of this policy

This policy is a statement of our own commitments and controls. It does not constitute legal advice, and it is not a warranty about the conduct of third parties. It is read alongside our Modern Slavery and Human Trafficking Policy and our terms and conditions.