Our position
We do not offer, give, ask for or accept bribes, in any form, anywhere. We would rather lose business than win or keep it by bribery.
This policy applies to everyone who works for us and to anyone who performs services for us or on our behalf, such as an agent or reseller.
The law
The Bribery Act 2010 makes it a criminal offence to offer, promise or give a bribe (section 1), to request, agree to receive or accept a bribe (section 2), and to bribe a foreign public official to obtain or keep business (section 6).
Under section 7, a commercial organisation commits an offence if a person associated with it bribes someone, intending to obtain or keep business, or an advantage in the conduct of business, for the organisation. An associated person is anyone who performs services for or on behalf of the organisation, such as an employee, contractor or agent. The organisation's only defence is to show that it had adequate procedures designed to prevent such bribery.
An individual convicted of bribery faces up to 10 years' imprisonment and an unlimited fine. An organisation faces an unlimited fine.
What counts as a bribe
A bribe is anything of value offered or given to induce or reward someone for performing their role improperly. It does not have to be money. It can be:
- cash, or a payment by any means;
- gifts, hospitality, travel or entertainment beyond what is reasonable and proportionate;
- a job, contract or work experience for a friend or relative;
- discounts, free licences or introduction payments that are not on proper commercial terms;
- a facilitation payment: a small, unofficial payment to speed up a routine action. These are bribes under UK law, and we do not make them.
Gifts and hospitality
Modest gifts and hospitality can be a normal part of business, but they must never influence a decision or look as if they might. Our rules are:
- Never give or accept cash or cash equivalents, such as vouchers or gift cards.
- Never give or accept anything while a contract, renewal, tender or price is being negotiated with that person's organisation.
- Record every gift or hospitality given or received that is worth more than £50 in our gifts register.
- Get the Director's approval before giving or accepting anything worth more than £100.
- Never offer anything to a public official without the Director's written approval.
- If in doubt, decline politely and tell the Director.
Our procedures
We follow the six principles in the government's guidance on adequate procedures under the Act, in a way that fits a small company:
- Proportionate procedures: this policy and our gifts register.
- Top-level commitment: the Director owns this policy and sets the standard.
- Risk assessment: at least once a year we review where bribery could arise, such as winning agency customers, choosing suppliers and any dealings with public bodies.
- Due diligence: we check who we are dealing with before we engage a supplier, agent or reseller, and include anti-bribery terms in our contracts with them.
- Communication: everyone who works for us reads this policy when they start and whenever it changes.
- Monitoring and review: the Director checks the gifts register and our payments, and reviews this policy each year.
Payments and records
Every payment we make goes to the business we owe, against an invoice or written agreement, and is recorded in our accounts. We make no payments off the books.
We do not make political donations. Any charitable donation needs the Director's approval, is recorded, and is never made to win or keep business.
Reporting a concern
If you are offered a bribe, asked for one, or suspect bribery by anyone connected with us, tell the Director at terry@hilliernet.co.uk or on 07789 938284 as soon as you can, and within 2 working days at most. Do not investigate it yourself.
You can also use our whistleblowing policy, or report serious or complex fraud, bribery or corruption to the Serious Fraud Office, which is a prescribed person under whistleblowing law.
No one will suffer for refusing to pay or accept a bribe, even if we lose business as a result, or for reporting a genuine concern.
Breaches
Anyone who works for us and breaks this policy will have their contract ended or, if we employ them, face disciplinary action, and we may report the matter to the police or the Serious Fraud Office. We end our relationship with any supplier, agent or customer that offers or pays a bribe. The Director reviews this policy at least once a year.
Anti-bribery and corruption · version 1.0 · approved 27/10/2026 · next review 27/10/2027. Templace is a trading name of TWH Holdings Limited, company number 10663539, Meadway, Mill Road, Writhlington, Radstock, BA3 5TY.