Anti-Bribery Policy
Our zero-tolerance approach to bribery and corruption.
1. Policy statement
The Proactive Group Limited conducts business honestly and ethically. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships, wherever we operate. This policy reflects our obligations under the Bribery Act 2010.
2. What is prohibited
No one acting for or on behalf of the firm may:
- Offer, promise or give a bribe — that is, any financial or other advantage intended to induce improper performance of a function or to secure business improperly;
- Request, agree to receive or accept a bribe;
- Bribe a foreign public official to obtain or retain business or an advantage;
- Make facilitation payments (small unofficial payments to speed up routine actions), which are illegal under UK law regardless of local practice.
3. Gifts and hospitality
Reasonable and proportionate hospitality given or received openly for legitimate business purposes — such as a modest working lunch — is acceptable. Gifts or hospitality that are lavish, frequent, offered during a tender or negotiation, or given secretly are not. Anything beyond modest value must be approved by a director and recorded.
4. Responsibilities and raising concerns
Preventing bribery is the responsibility of everyone working for or with the firm. Anyone who suspects bribery connected to our business must report it to a director as soon as possible. Concerns raised in good faith will be investigated and the person raising them will suffer no detriment, even if the concern turns out to be mistaken.
5. Consequences
Breach of this policy is treated as gross misconduct for employees and as grounds for immediate termination of contract for contractors, suppliers and associated persons. Bribery is a criminal offence carrying penalties including imprisonment and unlimited fines, for individuals and for the company.
6. Review
This policy is reviewed annually at director level and whenever the law or our business changes materially.