Anti-Corruption & Bribery Policy
1. Policy Statement
It is the SUMO Group of Companies policy to conduct our business in an honest & ethical manner. We take a zero tolerance approach to bribery & corruption and are committed to acting professionally, fairly and with integrity in all of our business deals & relationships wherever we operate, across the Group.
We will uphold all laws relevant to countering bribery and corruption including the Bribery Act 2010.
Bribery and corruption is punishable for individuals by up to ten years’ imprisonment and if a Company is found to have taken part in corruption the individual Company or Group could face an unlimited fine, be excluded from tendering for public contracts and face damage to reputation. We therefore take our legal responsibilities very seriously.
This Policy applies to all individuals working at all levels including Board Members, Directors, Senior Managers, employees (whether permanent, fixed term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, agency staff or any other person associated with the SUMO Group of Companies (collectively referred to as workers in this policy).
The SUMO Group Prohibits:
- The offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement
- To or from any person or company, wherever they are situated and whether they are a public official or body or private person or company
- By any worker on behalf of the Company
- In order to gain any commercial, contractual or regulatory advantage for the Sumo Group in a way which is unethical
- Or in order to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.
3. Gifts & Hospitality
This policy does not prohibit normal and appropriate hospitality given and received to or from third parties.
The giving and receiving of gifts or hospitality is acceptable if the following requirements are met:
i. It is not made with the intention of influencing a third party to obtain or retain business or a business advantage.
ii. It complies with the law
iii. It does not include cash or a cash equivalent (i.e. vouchers or gift cards)
iv. It is of an appropriate type and value and given at an appropriate time (i.e. ceremonial gift on a festival or another special time)
v. It is given openly & not secretly
Decisions as to what is acceptable may not always be easy. If you are in doubt as to whether a potential act constitutes bribery, the matter should be referred to your Director or the Group Managing Director.
4. Your Responsibilities
- You must ensure that you read, understand and comply with this policy
- The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the SUMO Group or under our control.
- You must notify your Line Manager, General Manager or Director as soon as possible if you believe or suspect that a conflict/breach with this policy has occurred. You will not suffer any adverse company action when doing so, and the matter will be dealt with in the strictest possible confidence.
- Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct, and may also be personally liable under the bribery act.
We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring 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 suspicions.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern. If you believe you have suffered any such treatment you should inform your Line Manager, General Manager or Director immediately. If the matter is not remedied and you are an employee you should raise it formally using our grievance procedure.
All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.