ANTI-BRIBERY AND CORRUPTION - THE BRIBERY ACT 2010
In the UK there have been legislative developments recently to tackle bribery and corruption. The Bribery Act 2010 will now come into force on 1st July 2011.
This Act has introduced a new obligation on all commercial organisations to prevent bribery taking place. A failure to have these procedures in place will mean that an offence is committed. This will have serious consequences for both this company and any individuals involved. The Act has a very wide application and can affect our activities around the world.
HTSPE already has a strict anti-bribery and corruption policy but an extended policy has been developed in conjunction with the company’s legal advisors to reflect this recent change in the law. HTSPE will not engage in bribery or corruption in any form and has a zero tolerance approach to breach whether it involves private individuals or government officials.
HTSPE will never (directly or indirectly) solicit, accept, agree to receive, promise, offer or give a bribe, facilitation payments, kick back or other improper payments. All of HTSPE's activities are managed in full compliance with this policy and all applicable legal and regulatory anti-bribery and corruption obligations (including the US Foreign Corrupt Practices Act and the UK Bribery Act).
HTSPE expects all its employees, associates, partners and team leaders to comply with the company's anti-bribery and corruption policy and the procedures set out therein.
If you are found to have given or accepted any bribe or to have acted in breach of HTSPE's anti-bribery and corruption policies and procedures, then you as an employee will face disciplinary action which could result in dismissal for gross misconduct and other associates, partners and team leaders who may not be employees of HTSPE will be considered (subject to appropriate investigation and enquiry) to be in breach of their contractual arrangements with HTSPE.
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