Corporate Social Responsibility
Corporate Social Responsibility (CSR)
Stoke Park recognises its ethical, social and economic responsibilities, which are integral to its business success. The companies within the group aim to demonstrate these responsibilities through their actions and corporate policies.
The senior management team is responsible for these policies and it makes the appropriate resources available to implement them, but it is the active support of all the employees of the group that make the successful implementation of these policies possible.
The International Group of companies has always attempted to be open, honest and have a positive impact on each of its stakeholders including its customers, employees, suppliers, business partners and the communities that its companies operate in.
In the UK the International Group of companies helps raise funds for a number of charities including the Vision Charity, Helen Rollason Cancer Fund, Golf Foundation, Variety Club, Christopher Place, Help the Hero’s, UK Youth, Princes Trust and Sports Aid. Overseas the group helps organise and supports local community and school projects.
Anti-Corruption and Bribery Policy
- Policy Statement
- Who is Covered by the Policy?
- What is Bribery and why is having an Anti-Bribery Policy Important?
- Gifts and Hospitality
- What is not acceptable
- Facilitation Payments and Kickbacks
- How to Raise a Bribery Concern
- Training and Communication
- Who is responsible for the policy and its implementation strategy?
- Monitoring and Review
|5||What is not acceptable|
|5.1||It is not acceptable for you (or someone on your behalf) to:|
|6||Facilitation Payments and Kickbacks|
|6.1||Facilitation payments are also known as 'grease' payments and are typically small or relatively small, unofficial payments made to secure or expedite a routine government action by a government official. They are not commonly paid in the UK, but are common in some other jurisdictions in which we operate.|
|6.2||We do not make, and will not accept, facilitation payments or "kickbacks" of any kind.|
|6.3||If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is as you would expect for the goods or service provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with your manager.|
|6.4||Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.|
|7.1||We may make contributions to political parties but these will never be made in an attempt to influence any decision or gain a business advantage and will always be publically disclosed. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the Chief Executive of International Group.|
|8||How to Raise a Bribery Concern|
|8.1||It is important that you report it by following the procedure set out in our Whistleblowing Policy as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity. A copy of our Whistleblowing Policy can be found at the Human Resources department.|
|8.2||If have any concerns about any issue with this policy or suspicion of bribery taking place, haven taken place, or could in the future take place, you should raise this at the earliest possible stage. Concerns should be reported by following the procedure set out in our Whistleblowing Policy.|
|8.3||If you are unsure whether a particular act is or could be bribery or corruption, or if you have any other queries, these should be raised with your line manager OR the Chief Executive of International Group as appropriate. We have set out a number of 'red flags' at Schedule 1 which provide you with an indication of some acts which could attract suspicion.|
|8.4||Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers and third parties if they breach this policy.|
|9.1||Workers who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We encourage openness and will support anyone who raises genuine concerns made in good faith under this policy, even if they turn out to be mistaken. However, if concerns are not genuine or are made in bad faith, employees may be subject to International Group's disciplinary procedure. We also reserve our right to terminate our contractual relationship with other workers if they breach this policy.|
|9.2||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 suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Chief Executive of International Group immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found at the Human Resources department.|
|10.1||We will keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.|
|10.2||You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.|
|10.3||All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments.|
|11||Training and Communication|
|11.1||Training on this policy forms part of the induction process for all new workers. All existing workers will receive regular, relevant training on understanding what bribery is, the risks we face as a business, and how to implement and adhere to this policy.|
|11.2||Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.|
|12||Who is responsible for the policy and its implementation strategy?|
|The Chief Executive of International Group Limited is responsible for this policy and its implementation working with the Human Resources department and all senior managers in the Group.|
|12.1||The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.|
|12.2||The Chief Executive at International Group Limited, who will report to the Board, has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it as set out in clause 11 above.|
|12.3||You have responsibility for ensuring that you comply with the policy and that you undertake our business in an ethical and anti-corrupt way. You also have responsibility for making sure that you report any bribery or corruption concerns by reporting it by following the procedure set out in our Whistleblowing Policy|
|12.4||This policy can be found at the Human Resources department and will also be accessible externally though our website.|
|13||Monitoring and Review|
The Chief Executive of International Group Limited will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. The policy will be reviewed at the quarterly Board Meeting, although review may be conducted earlier than this date in the event that circumstances require it. Any improvements identified as a result of a review or a report will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.
Last review date of the policy and procedure was 11th September 2013.
|13.2||All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.|
|13.3||Workers are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Human Resources department or the Chief Executive of International Group Limited.|
|Schedule - Potential Risk Scenarios: "Red Flags"|
The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
If you encounter any of these red flags while working for us, you must report them promptly using the procedure set out in the Whistleblowing Policy:
you become aware that a third party engages in, or has been accused of engaging in, improper business practices;
you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials;
a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
a third party requests an unexpected additional fee or commission to "facilitate" a service;
a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
a third party requests that a payment is made to "overlook" potential legal violations;
a third party requests that you provide employment or some other advantage to a friend or relative;
you receive an invoice from a third party that appears to be non-standard or customised;
a third party insists on the use of side letters or refuses to put terms agreed in writing;
you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;
you are offered an unusually generous gift or offered lavish hospitality by a third party.