Purpose and scope
This policy sets the anti-bribery standards for Giraffe Hosting Limited’s Giraffe Digital business. It applies to directors, employees and anyone authorised to act on our behalf, including contractors, agents and other representatives.
It supports compliance with the Bribery Act 2010 and other applicable law. The standards apply wherever work is carried out on our behalf.
Conduct that is prohibited
No person acting for us may offer, promise, give, request, agree to receive or accept a bribe. A bribe can involve money or another benefit intended to influence improper conduct or reward it. It can be provided directly or through another person.
- Do not offer personal rewards to influence a contract, referral, procurement decision or official action.
- Do not accept a benefit in return for giving someone an improper advantage.
- Do not use intermediaries, false invoices or hidden commissions to make an improper payment.
- Do not make facilitation payments to secure routine official actions.
Anyone facing a threat to their immediate safety should prioritise their safety and report the circumstances to management as soon as it is safe to do so.
Gifts, hospitality and other benefits
Reasonable, proportionate business hospitality can have a legitimate purpose. It must not be intended to influence a decision improperly, create an obligation or conceal a reward. The timing, value, frequency and circumstances all matter.
Cash gifts and cash equivalents must not be offered or accepted on our behalf. Anything that could reasonably create a conflict or appear to influence a live tender or decision must be declined or referred to management before it is offered or accepted.
Gifts or hospitality requiring a management decision must be recorded with the parties involved, the purpose, the approximate value and the outcome. If there is doubt, seek a decision before proceeding.
Business decisions and accurate records
Personal, financial or family interests that could affect a business decision must be disclosed to management. A person with a conflict should not make the relevant decision without an appropriate independent review.
Payments must be for genuine, agreed goods or services and supported by accurate records. Requests for unusual payment arrangements, undisclosed commissions or payments to an unrelated third party must be checked before payment.
Charitable donations, sponsorship and political contributions must not be used to obtain an improper business advantage. Any proposed contribution on our behalf requires management approval and an accurate record of its purpose and recipient.
Raise a concern
Report a suspected bribe, improper request or breach to Michael Swan at michael@giraffedigital.co.uk or 0333 090 9138. Include the relevant facts and retain information lawfully; do not put yourself at risk or investigate on your own.
If the concern involves your usual contact, you can address it in writing to the management of Giraffe Hosting Limited, 5th Floor, 167-169 Great Portland Street, London, W1W 5PF. You may also report suspected criminal conduct to the appropriate authority.
Concerns must be treated sensitively and shared only where necessary to review them, take action or meet legal obligations. No one should suffer retaliation for refusing a bribe or raising an honest concern, even if it is not substantiated.
Responsibility and review
Management is responsible for applying this policy, assessing relevant risks and deciding proportionate checks and action. Anyone representing the business must understand the standards relevant to their role and raise questions before acting.
A breach may lead to action under an applicable contract or disciplinary procedure, including ending a relationship where appropriate, and referral to the authorities. The response must take account of the facts and applicable law.
This policy will be reviewed at least annually and when a significant risk, legal change or reported concern makes an earlier review appropriate. Read About Giraffe Digital for our company details.