Preventing Bribery & Corruption

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

Click on the 'Info' button to find out more on each page!

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.

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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.

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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.

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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.

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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.

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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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