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What is bribery?
This is the act of offering something of value to influence a decision leading to an ultimate business advantage or benefit.
To be more specific, it refers to offering, giving, asking, promising, agreeing, receiving something of value to influence a behaviour, action or decision.
Hill Ash employees must not take part or engage in any form of bribery as it is an illegal act.
This anti-bribery policy sets out the responsibilities of Hill Ash and everyone who works for us to observe and uphold our zero-tolerance position on bribery and corruption.
Hill Ash is committed to conducting business in an ethical and honest way and is dedicated to implementing and upholding systems and processes that guarantee bribery is prevented. Hill Ash has zero-tolerance for bribery and corrupt activities. We act professionally and fairly in all business dealings and relationships.
Hill Ash will respect and uphold all laws in relation to anti-bribery and corruption in all the jurisdictions in which we operate. We work and are bound to the laws of the UK, including the Bribery Act 2010 relating to our behaviour and conduct both in the UK and overseas.
Hill Ash understands that bribery and corruption is not tolerated and punishable by up to ten years of imprisonment and a fine. If Hill Ash is found to have taken an active role in corrupt activities, we may be liable to an unlimited fine, face exclusion from tendering for public contracts, and receive negative public relations. With this in mind, we take our legal responsibilities very seriously.
Who this policy covers
This policy covers all employees and associated third parties:
Any agreements or arrangements Hill Ash makes with a third party is subject to clear contractual terms including the requirement for the third party to comply with minimum acceptable standards and procedures relating to anti-bribery and corruption.
Kickbacks and facilitation payments
We understand facilitation payments are a form of bribery and we will not accept or make any form of facilitation payments of any kind.
Kickbacks are not tolerated at Hill Ash. We recognise that kickbacks are made in exchange for a business advantage or favour.
Gifts and hospitality
We accept appropriate gestures of goodwill and hospitality. However, the giving and receiving of gifts must meet the following requirements:
On some occasions it may be inappropriate to decline an offer of a gift, e.g. when meeting with someone from another country who may take offence due to a different culture
All gifts given and received are disclosed to our compliance manager – especially those from suppliers.
We ensure our employees read, understand and comply with the information contained in this policy and any training or other anti-bribery and corruption information given.
If any of our employees breach this policy, they will face disciplinary action and face dismissal for gross misconduct. We have the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
Raising a concern
If you believe there is an instance of bribery or corrupt activities taking place in connection with Hill Ash, please express your concern as early as possible. We would ask that you speak with our compliance manager, Chris Rogers.
Political and charitable contributions
Hill Ash will not support any political parties by making improper donations in cash, or kind, to gain an improper business advantage.
We encourage raising and donating money for good causes that resonate with our business values. We disclose all charitable donations we make.
We ensure our employees understand charitable contributions are not used to facilitate and conceal acts of bribery.
Dealing with bribery or corruption
Please tell our compliance manager if you feel a bribe or corrupt behaviour is taking place in relation to Hill Ash. This might involve being offered a bribe or being coerced into making a bribe – or if you feel you are a victim of some form of corrupt activity.
Safeguarding and protection
As a result of refusing to accept or offer a bribe, Hill Ash will make sure no one receives adverse treatment due to reporting the concern.
Adverse treatment refers to disciplinary action, dismissal or detrimental treatment in connection to the concern raised.
Our anti-bribery and corruption policy will be clearly communicated to all employees, contractors, suppliers and third parties at the outset of any working relationship.
Hill Ash will record and keep accurate financial documents and have the necessary internal controls and processes in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.
Hill Ash is a beautiful family managed farm estate nestled in the foothills of the stunning South Downs National Park.
We are committed to ensuring there is no modern-day slavery or human trafficking in our supply chains or any part of the business.
Our anti-slavery policy statement reflects our commitment to acting ethically and with integrity in our business relationships. We will not support or deal with any business knowingly involved in slavery or human trafficking.
The senior management team shall take responsibility for implementing this policy statement and its objectives and provide adequate resources (training, etc.) to ensure that slavery and human trafficking is not taking place within the organisation or within its supply chains. The company’s anti-slavery policy will be displayed on the company website and on notice boards in the company office.
All new and existing employees are subjected to right to work checks to ensure that Hill Ash does not employ illegal workers thereby ensuring compliance with the Immigration, Asylum and Nationality Act 2006.
Employees are required to immediately report any possible breach of the code of conduct to their line manager or a member of the senior management team. This policy applies to all those employed by Hill Ash. The policy will be regularly reviewed by the senior management team to ensure its continuing suitability.