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Anti-Corruption and Bribery Policy

  1. Introduction
    1. Wido Limited (‘wido’) is a company incorporated in England and Wales and is a subsidiary of Bonnington Plastics Limited (‘BPL’) a company also incorporated in England and Wales.
    2. wido upholds all laws, including the United Kingdom (‘UK’) Bribery Act 2010 (‘Bribery Act’), relevant to countering bribery and corruption in all the jurisdictions in which it operates.
    3. This Policy is reviewed annually and was last reviewed in 29 August 2018.
  • About this Policy
    1. This Policy applies to all persons working for wido or on its behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located. It has been introduced to help anyone in those categories of persons to understand their responsibilities and understand where they and wido are vulnerable.
    2. The purpose of this Policy is to:
      1. ut the responsibilities of wido and of those working for wido in observing and upholding its position on bribery and corruption; and
      2. provide information and guidance on how to recognise and deal with bribery and corruption issues.
    3. It is a criminal offence under the Bribery Act to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years' imprisonment and/or a fine.
    4. If wido fails to prevent bribery, it can face an unlimited fine and damage to its reputation. It therefore takes its legal responsibilities very seriously.
    5. As a business which enters contracts for the supply of goods and services wido is vulnerable to bribery and corruption.
    6. In this Policy, ‘third party’ means any individual or organisation you encounter during the course of your work and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
    7. If you are an employee of wido, this Policy does not form part of your contract of employment and it may be amended it at any time.
  • Who is Responsible for the Policy?
    1. wido’s board of directors has overall responsibility for ensuring this Policy complies with its legal and ethical obligations and that it is observed.
    2. The compliance manager (‘Compliance Manager’) has day-to-day responsibility for implementing this Policy, monitoring its use and effectiveness, dealing with queries about it and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.
    3. The Compliance Manager can be contacted by email compliancemanager@widosupport.com.
    4. Management at all levels of wido are responsible for ensuring those reporting to them understand and comply with this Policy and are given adequate and regular training on it.
    5. You are invited to comment on this Policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Compliance Manager.
  • What are Bribery and Corruption?
    1. Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
    2. An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
    3. A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.
    4. Corruption is the abuse of entrusted power or position for private gain.
    5. The following are relevant examples:
      Offering a Bribe: You offer a potential client tickets to a major sporting event, but only if they agree to do business with wido.
      This would be an offence as you are making the offer to gain a business advantage. It may also be an offence for the potential client to accept your offer.
      Receiving a Bribe: A supplier gives your nephew a job but makes it clear that in return it expects you to use your influence in wido to ensure it continues to do business with them.
      It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.
      Bribing a Foreign Official: You arrange for wido to pay an additional ‘facilitation’ payment to a foreign official to speed up an administrative process, such as clearing its goods through customs.
      The offence of bribing a foreign public official is committed as soon as the offer is made because it is made to gain a business advantage for wido.
  • What You Must Not Do
    1. It is not acceptable for you (or someone on your behalf) to:
      1. give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage shall be received or to reward an advantage already given;
      2. give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;
      3. accept a payment, gift or hospitality from a third party that you know, or suspect is offered with the expectation that wido shall provide a business advantage for them or anyone else in return;
      4. accept hospitality from a third party that is unduly lavish or extravagant under the circumstances;
      5. threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this Policy; or
      6. engage in any other activity that might lead to a breach of this Policy.
  • Facilitation Payments and Kickbacks
    1. We do not make, and will not accept, facilitation payments or ‘kickbacks’ of any kind.
    2. ‘Facilitation payments’, also known as ‘back-handers’ or ‘grease payments’, are typically small, unofficial payments made to secure or expedite a routine or necessary action. They are not common in the UK but are common in some other jurisdictions.
    3. ‘Kickbacks’ are typically payments made in return for or following receipt of a business advantage.
    4. wido neither makes nor accepts ‘facilitation payments’ or ‘kickbacks’ of any kind.
    5. You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by wido or on its behalf, or that might suggest that such a payment shall be made or accepted.
    6. If you are asked to make a payment on wido’s behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided.
    7. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with Compliance Manager.
  • Gifts, Hospitality and Expenses
    1. This Policy does not prevent reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:
      1. establishing or maintaining good business relationships;
      2. improving or maintaining wido’s image or reputation; or
      3. marketing or presenting wido’s products and/or services effectively.
    2. The giving and accepting of gifts is allowed if the following requirements are met:
      1. it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
      2. it is given in wido’s name and not in your name;
      3. it does not include cash or a cash equivalent (such as gift certificates or vouchers);
      4. it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas;
      5. it is given openly, not secretly; and
      6. it complies with any applicable local law.
    3. Promotional gifts of low value such as branded stationery to or from existing customers, suppliers and business partners shall usually be acceptable.
    4. Reimbursing a third party's expenses or accepting an offer to reimburse its expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment more than genuine and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable.
    5. wido appreciates that practice varies between countries and what may be normal and acceptable in one country may not be acceptable in another. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. The intention behind the gift should always be considered.
  • Record-keeping
    1. wido must keep financial records and have appropriate internal controls in place evidencing the business reason for making payments to third parties.
    2. You must keep a written record of all hospitality or gifts given or received, which shall be subject to periodical managerial review.
    3. You must submit all expense claims relating to hospitality, gifts or payments to third parties in accordance with wido’s expenses policy and record the reason for expenditure.
    4. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept ‘off-book’; if this happened an attempt to facilitate or conceal improper payments would be suspected.
  • Your Responsibilities
    1. You must read, understand and comply with this Policy.
    2. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for wido. You are required to avoid any activity that breaches this Policy or might lead to, or suggest, a breach of this Policy.
  • How to Raise a Concern
    1. You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.
    2. If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption or other breach of this Policy has occurred or may occur, you must notify the Compliance Manager as soon as possible. For example, if a client or potential client offers you something to try and gain a business advantage with wido or indicates to you that a gift or payment is required to secure their business this should be notified to the Compliance Manager. Further ‘red flags’ that may indicate bribery or corruption are set out in paragraph 14.
    3. If you are unsure about whether a particular act constitutes bribery or corruption, raise it with the Compliance Manager.
  • Protection
    1. Individuals who refuse to accept or offer a bribe, or who raise concerns or report another's wrongdoing may be worried about possible repercussions. wido encourages openness and shall support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken.
    2. wido is committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
    3. If you believe that you have suffered any such treatment, you should inform the Compliance Manager immediately. If the matter is not remedied, you should raise it formally using the employee grievance procedure.
    4. The grievance procedure adopted by wido is that set out the employee handbook of its parent company BPL. If you do not have access to the BPL Employee Handbook, contact the Compliance Manager who will be able to provide a copy.
  • Training and Communication
    1. Training on this Policy forms part of the induction process for everyone who works for wido, and regular additional training shall be provided as necessary.
    2. If at any time you would like any guidance or additional training on this Policy, contact the Compliance Manager.
  • Breaches of this Policy
    A person working for wido who breaches this Policy shall face disciplinary action, which could result in termination of their employment contract for misconduct or gross misconduct.
  • Potential Risk Scenarios: ‘Red Flags’
    The following is a list of possible red flags that may arise during the course of you working for wido and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only. If you encounter any of these red flags while working for wido, you must report them promptly to the Compliance Manager.

    1. You become aware that a third party engages in, or has been accused of engaging in, improper business practices.
    2. You learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a ‘special relationship’ with foreign government officials.
    3. A third party insists on receiving a commission or fee payment before committing to sign up to a contract with wido or carrying out a government function or process for wido.
    4. A third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made.
    5. A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business.
    6. A third party requests an unexpected additional fee or commission to ‘facilitate’ a service.
    7. A third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services.
    8. A third party requests that a payment is made to ‘overlook’ potential legal violations.
    9. A third party requests that you provide employment or some other advantage to a friend or relative.
    10. You receive an invoice from a third party that appears to be non-standard or customised.
    11. A third party insists on the use of side letters or refuses to put terms agreed in writing.
    12. You notice that wido has been invoiced for a commission or fee payment that appears large given the service stated to have been provided.
    13. A third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to wido.
    14. You are offered an unusually generous gift or offered lavish hospitality by a third party.
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