Our Anti-Bribery and Anti-Corruption Statement
We believe that we don't have to be a large multinational with enormous budgets, to make choices that make sense for both the company's viability, and for those around us. This page is dedicated to explaining our commitment to avoid at all costs any bribery, corruption or other similar crimes.
Introduction
We are committed to the practice of responsible corporate behaviour and complying with all laws, regulations and other requirements which govern the conduct of our operations. We are regularly checking transactions, communications and interview staff to ensure we all remain fully committed to observing and upholding our no bribery and corruption principles.
Bribery
Bribery is defined as the giving or promising of a financial or other advantage to a party where that advantage is intended to induce them to perform a particular function improperly. Obviously the aim is to benefit the bribing party to any transaction.
Bribery is also deemed to take place if any party requests or agrees to receive a financial or other advantage from another party where that advantage is intended to induce that party to perform a particular function improperly, where the acceptance of that advantage is in itself improper in any way, or where said party acts improperly in anticipation or even hope of such advantage which may have been implied.
Responsibility for Compliance and Scope of Policy
This Policy applies to all employees, agents, contractors, subcontractors, consultants, business partners and clients, any other parties (including individuals, partnerships and bodies corporate) associated with us.
We hold all said parties to account and expect them to accept as their equal responsibility to ensure that bribery is prevented, detected and reported and all such reports should be made in accordance as otherwise stated in this Policy, as appropriate.
No party may:
Give or promise any financial or other advantage to another party (or use a third party to do the same), on the Company’s behalf where that advantage is intended to induce the other party to perform a particular function improperly, or where the acceptance of that advantage will in itself constitute improper conduct.
Request or agree to receive or give any financial or other advantage from another party where that advantage is intended to induce the improper performance of a particular function, where the acceptance of that advantage will in itself constitute improper conduct, or where the recipient intends to act improperly in anticipation of such an advantage.
All parties must:
Be reasonably aware and alert at all times of all bribery risks.
Exercise due diligence when dealing with third parties on behalf of our company; and report any and all concerns relating to bribery to their supervisors, or in the case of non-employees, their day to day point of contact within Upgrade Two Ltd.
Facilitation Payments
A facilitation payment is defined as a small payment made to officials in order to ensure or speed up the performance of routine or necessary functions.
Facilitation payments constitute bribes and may not be made at any time irrespective of prevailing business customs in certain territories.
Facilitation or similar payments may be made in limited circumstances where a parties' life is in danger but under no other circumstances.
Gifts and Hospitality
Gifts and hospitality remain a legitimate part of conducting business provided that none is accepted without the wider knowledge of every involved party’s supervisors, and cannot be accepted without it being published on the public domain (thus giving any interested party the opportunity to object).
All involved parties must consider that gifts and hospitality can, when excessive, constitute a bribe and/or a conflict of interest. Care and due diligence should be exercised at all times when giving or receiving any form of gift or hospitality on behalf of Upgrade Two Ltd.
The following general principles apply:
Gifts and hospitality may neither be given nor received as rewards, inducements or encouragement for preferential treatment or inappropriate or dishonest conduct.
Neither gifts nor hospitality should be actively sought or encouraged from any party, nor should the impression be given that the award of any business, custom, contract or similar will be in any way conditional on gifts or hospitality.
Cash should be neither given nor received as a gift under any circumstances.
Gifts and hospitality to or from relevant parties should be completely avoided at the time of contracts being tendered or awarded.
The value of all gifts and hospitality, whether given or received, should be proportionate to the matter to which they relate and should not be unusually high or generous when compared to prevailing practices in our industry or sector.
Certain gifts which would otherwise be in breach of this Policy and/or the Hospitality and Gifts Policy may be accepted if refusal would cause cultural offence, however the Company will donate any gifts accepted for such reasons to a charity of the directors’ choosing.
All gifts and hospitality, whether given or received, must be recorded in the Hospitality & Gifts Register.
Charitable Donations
Charitable donations are permitted only to registered (non-profit) charities. No charitable donations may be given to any organisation which is not a registered charity. It is noted that Upgrade Two Ltd. is currently the owner of Upgrade2Trees product, which is currently generally geared to not make any notable profit from its operation and the selling/offering of trees to be planted. All accounts for Upgrade2Trees are open for public examination at any time and upon simple request from any party. Therefore donations to planting trees via Upgrade2Trees will be accepted, although this will not be the case if the planting of trees is done at a time and by a party which are very closely involved to any tender that may be run by us.
All charitable donations must be fully recorded and communicated to supervisors of our company.
Proof of receipt of all charitable donations must be obtained from the recipient organisation.
No charitable donation may be made at the request of any party where that donation may result, or is suspected to result, in improper conduct.
Political Donations
The Company does not make political donations at all, ever.
Employees and other associated parties are free to make personal donations as per the applicable laws but such payments cannot be made on behalf of Upgrade Two Ltd. or any other person within the organisation. In addition, they cannot be made to obtain any form of advantage in any business transaction.
Consequences of Bribery and Corruption
Failure to comply may result in penalties Upgrade Two Ltd., including fines, legal action, reputational damage, and loss of business, and the company therefore maintains the right to seek compensation from the individual or party that has been involved in such behaviour.
Individuals who violate the UK Bribery Act, or other anti-bribery laws will be personally liable and subject to fines and/or imprisonment. Every employee of Upgrade Two Ltd. is expected to immediately report such behaviour when observed.
Thank you for helping us do the right thing.