ANTI-BRIBERY POLICY

This document sets out the firm’s policy in relation to bribery and corruption and applies strictly to all employees’ consultants, contractors and other people and bodies associated to Gulbenkian Andonian in all areas, regions and functions.

Acts of Bribery or corruption are designed to influence an individual or group of people in the performance of their duty and to incline them to act in a way that could be considered dishonest in the circumstances.

Bribery can be broadly defined as offering, promising or giving financial or other advantage to a person with the intention of inducing or rewarding that person to act or to have acted in a way considered improper in the circumstances.

Bribes can include but are not limited to money, gifts hospitality and entertainment if they are intended to influence the decision of an individual.

Under the Bribery Act 2010 which came into force on 1.7.2011 individuals are punishable by up to 10 years imprisonment and/or an unlimited fine. If the firm is found to have taken part in the bribery or is found to have inadequate procedures in place to prevent bribery it could also face an unlimited fine. This would have severe reputational and /or financial consequences for the firm.

Gulbenkian Andonian Solicitors will not tolerate bribery in any form. We prohibit the offering, giving, solicitation of any bribe or corrupt inducement in any form be it to or from any person or company wherever located, whether a public or private individual to or from any person or company or by any person employed by the firm or acting on the firms behalf. We further prohibit any offering be it to or from any member of the firm to gain any contractual, commercial or regulatory advantage or any personal advantage for any individual or persons connected to the individual.

The policy is not designed to prohibit the following where they are appropriate and propionate and where properly recorded:

  • Normal hospitality providing it can be shown it was not for any gain for any individual.
  • Any ‘fast track’ service which is available to all on the payment of a fee.

As it may not always be a simple matter to determine whether a course of action is appropriate, if an individual is in any doubt that they or a colleague may be in breach of the policy they should refer to the firm’s Compliance Officer for Finance and Administration.

The prevention, detection and reporting of bribery is the responsibility of all employees and if there is suspicions that any form of bribery has or is taking place then it is the duty of all employees and staff to report this.

The firm will thoroughly investigate any actual or suspected breach. Any employees found to be in beach may be subject to disciplinary action which may result in their dismissal.