1. Policy Statement
Eltron Europe Ltd has a zero-tolerance approach to bribery and corruption. The offering, giving, receiving, or soliciting of any gift, loan, payment, reward, or advantage for personal gain, with the intention to influence a dishonest, illegal, or unethical outcome, is strictly prohibited.
We are fully committed to conducting our business with the highest standards of integrity, transparency, and professionalism, and in full compliance with applicable anti-bribery laws, including the UK Bribery Act 2010.
2. Our Commitment
- Eltron Europe Ltd will not tolerate bribery or corrupt practices in any form, whether carried out by employees or by third parties acting on our behalf.
- We promote a culture of honesty and strong moral principles in every area of our operations.
- All employees, contractors, and third-party representatives are expected to uphold this policy and act in accordance with it at all times.
3. What Constitutes Bribery
Bribery involves giving, offering, receiving, or soliciting something of value to influence a decision or action that is dishonest, illegal, or a breach of trust. This may include:
- Offering or accepting a bribe.
- Bribing a foreign public official.
- Failing to prevent bribery by associated persons (corporate offence).
- Any misuse of position or power for personal or organisational gain.
Examples include money, gifts, meals, entertainment, services, or any other benefit offered to gain an unfair advantage.
4. Legal Consequences
Under the Bribery Act 2010:
- Individuals found guilty can face up to 10 years in prison and/or unlimited fines.
- Companies can face unlimited corporate fines for failing to prevent bribery.
5. Scope of the Policy
This policy applies to:
- All employees, regardless of position or location.
- All individuals acting on behalf of Eltron Europe Ltd, including contractors, agents, consultants, and temporary staff.
6. Prohibited Conduct
It is strictly prohibited to:
- Offer, give, request, or accept any bribe — whether in cash or in kind — to gain any personal or business advantage.
- Make facilitation payments to foreign public officials or others, either directly or through a third party.
- Act in a way that could be perceived as an attempt to influence a decision unfairly.
Note: If you feel coerced into agreeing to a bribe due to immediate threats to personal safety, report the matter to a Director as soon as possible.
7. Reporting Bribery or Suspicious Activity
If you are offered a bribe, or suspect bribery or corruption (even if you are not directly involved), you must immediately report the matter to a Company Director. You may be asked to submit a written report detailing the incident.
8. Due Diligence on Third Parties
Before engaging with new suppliers, partners, or third-party representatives, Eltron Europe Ltd will conduct appropriate due diligence to ensure they align with our anti-bribery principles.
9. Donations and Sponsorships
Any charitable donations or sponsorships made by Eltron Europe Ltd will be done transparently and in good faith. No contribution will be made with the intention of influencing a business decision or gaining an unfair advantage.
10. Disciplinary Action
Any employee found in breach of this policy may face disciplinary action, up to and including dismissal.
Similarly, our agreements with contractors or agency staff may be terminated if they are found to have violated this policy.
11. Gifts and Hospitality
We recognise that appropriate gifts and hospitality can help build positive business relationships. However:
- Gifts such as event tickets, cash, vouchers, flowers, food, drink, loans, or services may only be given or received where there is no expectation of a return favor or business advantage.
- Hospitality, such as meals or events, is acceptable only when hosted in a business context. If the host is not present, it will be treated as a gift.
Important:
No gift or hospitality should be offered or accepted without prior written approval from a Company Director.
12. Policy Review
As laws and regulations may change over time, Eltron Europe Ltd reserves the right to amend this policy without prior notice. Regular reviews will be conducted to ensure continued compliance with anti-bribery legislation.