Anti-bribery Policy – 2022
1) What does this policy cover?
a) This anti-bribery policy exists to set out the responsibilities of Netmarque Ltd trading as Big Picture and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.
b) It also exists to act as a source of information and guidance for those working for us. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.
2) Policy Statement
a) Netmarque Ltd trading as Big Picture is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Netmarque Ltd trading as Big Picture has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.
b) Netmarque Ltd trading as Big Picture will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.
c) Netmarque Ltd trading as Big Picture recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.
3) Who is covered by the policy?
a) This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.
b) In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
c) Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.
4) Definition of bribery
a) Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.
b) A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.
c) Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
d) Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.
5) What is and what is NOT acceptable
a) This section of the policy refers to 4 areas:
i) Gifts and hospitality.
ii) Facilitation payments.
iii) Political contributions.
iv) Charitable contributions.
b) Gifts and hospitality
(a) Netmarque Ltd trading as Big Picture accepts normal and appropriate gestures of hospitality and goodwill (whether given to /received from third parties) so long as the giving or receiving of gifts meets the following requirements:
ii) It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
iii) It is not made with the suggestion that a return favour is expected.
iv) It is in compliance with local law.
v) It is given in the name of the company, not in an individual’s name.
vi) It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
vii) It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
viii) It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
ix) It is given/received openly, not secretly.
x) It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
xi) It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).
xii) It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.
c) Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/ culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.
d) Netmarque Ltd trading as Big Picture recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.
e) As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.
f) The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.
g) Facilitation Payments and Kickbacks
i) Netmarque Ltd trading as Big Picture does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
ii) Netmarque Ltd trading as Big Picture does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.
iii) Netmarque Ltd trading as Big Picture recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put
their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:
(1) Keep any amount to the minimum.
(2) Ask for a receipt, detailing the amount and reason for the payment.
(3) Create a record concerning the payment.
(4) Report this incident to your line manager.
h) Political Contributions
(a) Netmarque Ltd trading as Big Picture will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.
i) Charitable Contributions
i) Netmarque Ltd trading as Big Picture accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.
ii) Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
iii) We will ensure that all charitable donations made are legal and ethical under local laws and practices and that donations are not offered/made without the approval of the compliance manager.
j) Exceptional Circumstances
i) In some circumstances a payment is justifiable.
(1) If one of our people is faced with a threat to their personal safety or that of another person if a payment is not made, they should pay it without fear of recrimination. In such cases must be contacted as soon as possible, and the payment and the circumstances in which it was made must be fully documented and reported. will consider carefully whether to involve the police.
ii) Such cases will be rare. All our people visiting regions where these cases are more common should familiarise themselves, prior to travel, with current guidance relating to those countries. For general information on travelling to a particular country, please consult the latest information from the UK Government.