gne Anti-Bribery Policy (covering the giving and receiving of bribes)

Introduction:

gne values its reputation for ethical behaviour and it recognises that over and above the committing of any crime, any involvement in bribery will also reflect adversely on its image and reputation. gne therefore aim to limit its exposure to bribery by:-

  • Setting out a clear anti-bribery policy
  • Training all employees so that they can recognise and avoid the use of bribery by themselves and others
  • Encouraging employees to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately
  • Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resulting prosecution
  • Taking firm and vigorous action against any individual(s) involved in bribery
The Policy

gne 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 individual employee, agent or other person or body acting on the company's behalf

in order to : gain any commercial, contractual or regulatory advantage for the Group in a way which is unethical

Further Clarification

This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the company or of the person or body employing them or whom they represent.

This policy is not meant to prohibit the following practices providing they are customary, are proportionate and are properly recorded:

  • normal and appropriate hospitality
  • the giving of a ceremonial gift on a festival or at another special time
  • the offer of resources to assist the person or body to make the decision more efficiently provided that they are supplied for that purpose only
  • Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to a Director with responsibility for this policy before proceeding.

    Employee Responsibility

    The prevention, detection and reporting of bribery is the responsibility of all employees throughout the company. Suitable channels of communication by which employees or others can report confidentially any suspicion of bribery are to their line manager, a Director, or the HR Manager.

    Corporate Business Values


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