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Eynsham Hall Bribery Policy

ANTI-BRIBERY POLICY

Eynsham Hall Ltd values its reputation and is committed to trading within the law while maintaining the highest possible ethical standards in all its business activities. It recognises that the risks from bribery are a growing concern of corporate and public life in many countries across the world. Eynsham Hall, in its ongoing efforts to keep its high ethical standards and with a view to upholding its position against any form of bribery, has prepared and set out a clear policy which should be implemented in conjunction with the company’s Code of Ethics and Business Conduct (“the Code”).

Purpose and Scope

The purpose of the policy is to set out the responsibilities of Group functions and business units in observing and upholding the company’s position on bribery and applies to all Eynsham Hall staff (staff, contract and temporary), within all areas and functions, its agents, consultants and business partners.

Acts of bribery and corruption are illegal and, on conviction, may result in individuals and their employers being subject to criminal sanctions including fines and/or imprisonment.

Policy

Eynsham Hall 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, whether they are a public official or public body, or private person or company, wherever situated; or.

by any individual employee, agent or other person or body acting on Eynsham Hall’s behalf; or

in order to gain any commercial, contractual or regulatory advantage for Eynsham Hall’s in a way which is unethical: or

in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone

connected with the individual.

For the avoidance of doubt, Eynsham Hall prohibits

• the making of facilitation payments to government officials (typically used for securing or accelerating routine government procedures); or

• making a payment to any other business contact to secure a commercial advantage; or

• authorising or providing travel benefits, gifts, entertainment, or political contributions for the benefit of a Government Official or other business contact without compliance with the Eynsham Hall policies on business hospitality and gifts or failing to follow due diligence procedures; or

• entering into a consultant or sales agent agreement that will result in contacts with Government Officials or other business contact without conducting due diligence, obtaining the required internal business and legal approvals, retaining all due diligence for eight years, and accurately recording on Eynsham Hall’s book and records all related payments; or

• making any incomplete, false or inaccurate entries on Eynsham Hall’s books and records.

Responsibilities

The prevention, detection and reporting of bribery is the responsibility of all employees throughout Eynsham Hall Ltd. If any instance of bribery is identified, remedial steps will be taken immediately. Managers should ensure all their employees are aware of this policy and their responsibilities to act in accordance with its procedures.

Raising Concerns and Seeking Guidance

The company’s Whistle Blowing policy provides details of who to contact should you have any concerns or doubts as to whether a potential act constitutes bribery.

March 2012