ADWAY ASSOCIATES – EXECUTIVE SEARCH LTD (‘the Company’) 

ANTI-BRIBERY AND CORRUPTION POLICY 

Adway Associates – Executive Search Ltd ‘the Company’ is committed to the highest standards of ethical conduct and integrity in its business activities. This policy outlines the Company’s position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. The Company will not tolerate any form of bribery by, or of, its employees, supplier, customer or any person or body acting on its behalf. The Managing Director is committed to implementing effective measures to prevent, monitor and eliminate bribery. 

Introduction 

This policy applies to all employees, and to temporary workers, consultants and contractors. Every employee and associated person acting for, or on behalf of the Company is responsible for maintaining the highest standards of business conduct. Any breach of this policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of the Company. 

The Company may also face criminal liability for unlawful actions taken by its employees or associated persons under the Bribery Act 2010. All employees and associated persons are required to familiarise themselves and comply with this policy, including any future updates that may be issued from time to time by the Company. The Bribery Act 2010 is in force from 1 July 2011 to present. 

The Bribery Act 2010 

The Company is committed to complying with the Bribery Act 2010 in its business activities. 

Under the Bribery Act 2010, a bribe is a financial or other type of advantage that is offered or requested with the intention of inducing or rewarding improper performance of a function or activity; or knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity. 

A relevant function or activity includes public, state or business activities or any activity performed during a person’s employment, or on behalf of another company or individual, where the person performing that activity is expected to perform it in good faith, impartially, or in accordance with a position of trust. 

A criminal offence will be committed under the Bribery Act 2010 if: 

• An employee or associated person acting for, or on behalf of, the Company offers, promises, gives, requests, receives or agrees to receive bribes; or 
• An employee or associated person acting for, or on behalf of, the Company offers, promises or gives a bribe to a foreign public official with the intention of influencing that official in the performance of his/her duties (where local law does not permit or require such influence); and the Company does not have the defence that it has adequate procedures in place to prevent bribery by its employees or associated persons. 

All employees and associated persons are required to comply with this policy, in accordance with the Bribery Act 2010. 

Gifts and Hospitality 

Gifts and hospitality can, when excessive, constitute a bribe and/or conflict of interest. The 

value of all gifts and hospitality should not be unusually high or generous when compared to 

prevailing practices in our industry. They should be generally avoided at the time of contracts 

being tendered or awarded. All gifts and hospitality must be recorded in a register for this purpose. 

Gifts 

• Except for gifts of low value and which are mere tokens (such as promotional pens, calendars and stationery), employees are not permitted to accept any gifts from customers, suppliers or third parties involved with the Company. 

• Where refusing a gift could cause offence or embarrassment, the gift may be accepted and donated to a charity of the Company’s choice. 

• Approval must be sought from the Managing Director before accepting any gift. 

• Cash should not be given or received as a gift under any circumstances. 

Hospitality 

‘Corporate Hospitality’ is defined here as any form of accommodation, entertainment or other hospitality provided for an employee solely due to his/her position as a representative of the Company. The following are not considered Corporate Hospitality and don’t require any approval: 

• Normal working lunches or refreshments provided during a business visit. 

• Hospitality provided at a company approved seminar or industry events such as recruitment dinners so long as the hospitality is extended to all attendees. 

• Free seminars, talks or workshops, provided they are free to all attending. 

All other forms of Corporate Hospitality require approval from the Managing Director before acceptance. 

Remember that market practice varies between countries and what is normal and acceptable in one place may not be in another. If you are in doubt about the appropriateness of a gift or hospitality, please refer the matter to the Managing Director. 

Breach of Policy 

The Company will investigate seriously any actual or suspected breach of this policy or the spirit of this policy. Staff may be subject to a disciplinary action which may ultimately result in their dismissal. In the case of the third parties found to be bribing or attempting to bribe our employees, a supplier or customer, they will be informed in writing that business dealings will be ceased and appropriate authorities informed.