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Bribery Act Policy

Explanation – Bribery Act 2010 

 

Bribery can be defined as an inducement or reward offered, promised or provided in order to gain commercial, contractual, regulatory or personal advantage.  

 

The Bribery Act 2010 applies to both the private and public sectors. There are severe penalties for any employee convicted under the Act including 10 years’ imprisonment and unlimited fines. 

 

Purpose of the policy – zero tolerance  

 

This policy sets out Strive Higher’s responsibilities and those of its employees and others associated with Strive Higher in upholding our position of zero tolerance towards bribery and corruption. It is also intended to provide guidance for employees and others on how to recognise and deal with bribery and corruption issues. 

 

Prohibition 

 

All Strive Higher employees and associates are prohibited from: 

  • Offering, promising, or giving a bribe. 

  • Requesting, agreeing to receive, or accepting a bribe. 

  • Bribing a foreign public official to gain a business advantage. 

 

Gifts and hospitality 

 

Employees are forbidden to offer or accept gifts and hospitality that could affect the impartiality of the giver or receiver, influence a business decision, or lead to the improper performance of an official duty. Similarly, they may not offer or accept donations in cash or cash-equivalents such as vouchers. 

 

Facilitation payments 

 

Facilitation payments, which are small payments made to secure or expedite a routine action by an official, are considered bribes and are strictly prohibited. 

 

Due diligence 

 

Strive Higher will conduct due diligence on third parties, clients, partners and suppliers before entering into any business relationship to ensure that they are committed to anti-corruption and anti-bribery principles. 

 

Record-keeping 

 

All Strive Higher financial transactions are accurately recorded in the company's books and records. Falsifying records or misrepresenting transactions related to bribery or corruption is strictly prohibited. 

 

Reporting 

 

Employees and associates are encouraged to report any suspicious activities or breaches related to this policy. Strive Higher ensures that all reports will be treated confidentially and that there will be no retaliation against anyone who reports in good faith. 

 

Training and awareness 

 

Strive Higher will provide regular training and resources to ensure all employees and associates are aware of this policy, understand what constitutes bribery and corruption, and know how to avoid and report any related issues. 

 

Compliance and monitoring 

 

Regular audits and reviews will be conducted to ensure adherence to this policy. Any breaches will be addressed promptly, and appropriate action, including disciplinary measures, will be taken. 

 

 

Strive Higher expects all employees, associates and anyone associated with us to uphold this Anti-Bribery Policy. Our reputation and success rely on our collective commitment to operate ethically and legally at all times. 


Statement Date: 12 January 2024

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