Preventing Bribery & Corruption
Emily Meredith
Created on October 14, 2024
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Transcript
Preventing Bribery & Corruption
Acorn by Synergie processes
Introduction
In this presentation, you will learn all about:
- How we minimise the risk of bribery & corruption
- Our policies, procedures & forms
- How we ensure that we operate ethically
Risk Assessment
- We undertake a thorough risk assessment which is reviewed regularly.
- We interview those most at risk to identify any gaps in our processes and to make improvements where required. People who are involved in sales, bids & tenders are likely to be most at risk.
+ Info
Robust Policies & Procedures
Our expectations are clearly set out in the following documents:
- Anti Bribery Policy
- Synergie Code of Ethics and Business Conduct
- Gifts & Hospitality Procedure
Financial Controls
Many people have access to the payment processes for candidates, clients & suppliers it's very important that controls are in place. These include:
- Segregation of duties - meaning that different people have responsibility for different parts of a process.
- Levels of approval are in place for different levels of spend.
- An expenses system to process, upload and approve claims.
- Centralised systems to control client and candidate processes (Bullhorn, Sirenum, Tempest etc.)
- Robust payroll and accounting processes.
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Communication & Training
- All employees undergo anti-bribery & corruption training.
- We have a dedicated anti-bribery & corruption page on the intranet.
- We make sure you are updated if there are any changes to processes & legislation.
+ Info
Receiving gifts & invitations
- If you receive a gift from a candidate, client or supplier, it must be declared via email to complianceofficer@acornpeople.com and will be logged on a Gift Register.
- If you receive an invitation from a candidate, client, or supplier it must be declared via email to complianceofficer@acornpeople.com.
- Cash gifts can never be accepted.
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Corporate Hospitality
- Cannot be offered in exchange for business and should not influence business decisions.
- Must be approved in advance by MD and / or COO via a Corporate Hospitality Request Form.
- Cannot be lavish or extravagant.
- Should be booked centrally via the Marketing team.
- If claiming expenses for client entertaining, the company name and names of the attendees must be included.
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Giving Gifts
- Corporate gifts are selected & purchased via the Marketing team.
- Employees are able to purchase small gifts (up to the value of £10 per client). Expense claims must contain the name of the client and recipient of the gift.
- Total spend cannot exceed £50 per client in a tax year.
- Requests for gifts of more than £10 must be authorised by the MD and or COO.
+ Info
Conflicts of Interest
- This is when personal interests overlap with business interests and could affect your judgement or decision making e.g. if a family members works for a client or supplier.
- All new employees complete a Conflict of Interests Declaration prior to starting.
- All employees complete an annual Conflict of Interests Declaration.
- The SMT review all Conflicts of Interest and set out appropriate actions.
Customers & Suppliers
- All customers must sign a Terms of Business and it must be relevant to the service we are providing e.g. temp, perm, CIS etc.
- We have an in-depth Supplier Questionnaire and we carry out thorough due diligence on all suppliers.
+ Info
Sponsorship
- All requests for sponshorship must be made via a Sponsorship Request Form.
- This applies to all kinds of sponsorship e.g. sports teams, awards, events etc.
- Requests for sponsorship will be screended by Marketing and must be approved by the MD and/or COO.
+ Info
Whistleblowing & reporting
- We have an open & honest culture where people can raise and report any concerns.
- Synergie also has an anonymous whistleblowing platform - https://synergie.integrityline.com/?lang=en
Auditing & Continuous Improvement
- Synergie carry out an annual anti-bribery & corruption audit and suggest areas for improvement.
- We also have external audits from our accountants and could be audited by an external compliance body at any time.
- We are always looking to improve our processes to minimise the risks to us and our customers.
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