Anti-bribery Policy

Policy Details

Under the Bribery Act 2010, it is an offence to offer, promise or give any financial or other advantage to another person with the intention of causing that person to improperly carry out a function or activity from which the business will gain an advantage.

This policy applies to all employees of Manifest and those associated with the organisation. During your employment, all activities connected to your role and the wider business or conducted on behalf of third parties such as clients and suppliers, must be carried out impartially and in good faith.

Manifest employees must not request, anticipate, agree to receive or receive any financial or other advantage as a reward for improperly carrying out a function or activity.

The Company prohibits the bribing of UK or foreign public officials to win or retain business, speed up an action or to gain an advantage in any activity connected to the business.

The giving and receiving of hospitality or business gifts where the intention is to receive an advantage in return is not permitted.

Offers of business gifts should be referred to a Director and only be accepted if cleared by that person.

If you wish to give a business gift to a third party(e.g. a client or supplier), you must only do so with the permission of a Director and you must keep records of any gifts made or received. Cash gifts are not permitted.

Hospitality should be reasonable and proportionate to the nature of the business relationship. Acceptable types of hospitality include business lunches/dinners or attending sporting/cultural events, where the intention is to build business relationships rather than to receive or provide an advantage.

The provision of small gifts and promotional items (pens, diaries, mugs etc.) is also acceptable.

Employees responsible for reviewing or signing-off expense claims should be made aware of any hospitality or gifts provided and report any concerns about potential bribery to a Director.

Donations to political parties are not permitted. Any charitable donations must be done with the consent of a Director and awarded without the expectation of reward.

If you are concerned about acts or potential acts of bribery, you should speak to your line manager in the first instance. He/she will then raise this with a Director, as appropriate. Any reports of bribery will be treated in confidence.

© Manifest 2023