Bribery Policy

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Policy Statement:
Swift Tech Services is committed to conducting business ethically and with integrity. Bribery and corruption in any form are unacceptable and undermine the trust and integrity we strive to maintain with our clients, suppliers, and business partners. This policy outlines our zero-tolerance approach to bribery and provides guidance on how to recognize, prevent, and report instances of bribery within our organization.
 

Scope:
This policy applies to all directors, employees, contractors, and any other individuals representing Swift Tech Services.
 

Policy:
1. **Definition of Bribery:**
Bribery is the offering, giving, receiving, or soliciting of anything of value as a means to influence the actions of an individual or entity in a business or governmental context.
 

2. **Prohibited Activities:**
a. Offering, giving, receiving, or soliciting bribes, kickbacks, or other illicit payments, whether directly or indirectly, to or from any person or entity.
b. Making facilitation payments, even if they are customary in a particular country or industry.
c. Engaging in any activities that could be perceived as bribery, even if no financial transaction is involved.
 

3. **Compliance with Anti-Bribery Laws:**
Swift Tech Services and all individuals associated with the company must comply with all applicable anti-bribery laws and regulations, including but not limited to the UK Bribery Act 2010.
 

4. **Gifts, Entertainment, and Hospitality:**
a. All gifts, entertainment, and hospitality offered or received in the course of business must be modest, transparent, and in compliance with company policies and applicable laws.
b. Employees must obtain approval from their line manager before offering or accepting any gifts, entertainment, or hospitality with a value exceeding [company-specific threshold].
 

5. **Conflict of Interest:**
Employees must disclose any actual or potential conflicts of interest that may arise from personal, financial, or other relationships with suppliers, clients, or other parties with whom Swift Tech Services conducts business.
 

6. **Training and Awareness:**
Swift Tech Services will provide regular training and awareness programs to ensure all employees and contractors understand their obligations under this policy and are equipped to recognize and prevent bribery.
 

7. **Reporting and Whistleblowing:**
Any employee who becomes aware of or suspects bribery or corruption must report it immediately to their line manager, the Compliance Officer, or through the company's whistleblowing procedures. Reports will be investigated promptly and confidentially, and appropriate action will be taken.
 

Enforcement:
Violation of this policy may result in disciplinary action, up to and including termination of employment or contract, as well as legal consequences in accordance with applicable laws.
 

Review:
This policy will be reviewed regularly to ensure its effectiveness and compliance with relevant laws and regulations.
 

Approval:
This policy has been approved by Simon Whitney on 6th May 2024.

Contact Swift Tech Services on 01273 927091