Anti-Bribery Policy

Anti-Bribery Policy Date: 10/09/2024

1. Introduction

Quality Waste is committed to conducting its business with integrity and transparency. This Anti-Bribery Policy outlines our zero-tolerance approach to bribery and corruption, ensuring compliance with the Bribery Act 2010 and other relevant laws and regulations.

2. Purpose

The purpose of this policy is to:

• Prevent bribery and corruption in all areas of our operations.
• Promote ethical conduct and transparency in our business dealings.
• Ensure compliance with the Bribery Act 2010 and other applicable laws.

3. Scope

This policy applies to all employees, contractors, suppliers, and business partners of Quality Waste, whether based in the UK or internationally.

4. Definitions

• Bribery: Offering, giving, receiving, or soliciting something of value as an inducement or reward for improper performance of a function or activity.
• Corruption: Abuse of power or position for personal gain, which includes bribery, fraud, and other forms of unethical conduct.

5. Policy Statement

Quality Waste prohibits:

• Offering, giving, or receiving bribes or improper payments, directly or indirectly.
• Engaging in any activity that could be perceived as a bribe or improper inducement.
• Using intermediaries or agents to facilitate bribery or corrupt practices.

6. Responsibilities

Employees are expected to:

• Avoid any form of bribery or corrupt practices in their professional conduct.
• Report any suspected bribery or corruption to their line manager or the designated compliance officer.
• Seek guidance if they are unsure whether a particular action or offer could be considered a bribe.

Managers and Supervisors are expected to:

• Ensure that their teams understand and comply with this policy.
• Monitor business practices to detect and prevent bribery and corruption.
• Take appropriate action to address any breaches of this policy.

7. Gifts and Hospitality

Gifts and hospitality may be given or received only if they are:

• Not intended to influence business decisions improperly.
• Reasonable and proportionate in value.
• Recorded in the company’s register of gifts and hospitality.

8. Facilitation Payments

Facilitation payments are prohibited. These are small payments made to expedite routine governmental actions, which are considered as bribes under the Bribery Act 2010.

9. Third Parties

We require that all third parties, including suppliers and business partners, adhere to similar anti-bribery and anti-corruption standards. Due diligence will be conducted to ensure compliance.

10. Reporting and Whistleblowing

Employees who suspect bribery or corruption should report their concerns using the company’s whistleblowing procedures. Reports can be made confidentially and will be investigated promptly.

11. Training and Communication

All employees will receive training on this policy and bribery prevention. Regular communication and updates will ensure ongoing awareness and compliance.

12. Monitoring and Review

This policy will be reviewed annually and updated as necessary to ensure its effectiveness and compliance with legal requirements. Employees will be informed of any changes.

13. Contact Information

For questions about this policy or to report concerns, please contact HR Department.