Anti-Bribery & Anti-Corruption Policy
1. What does this policy cover?
1.1 The purpose of this anti-bribery policy is to clarify the obligations of Urbanvex and its personnel in relation to our unwavering commitment to combating bribery and corruption.
1.2 Additionally, it provides essential information and guidance to assist employees in identifying and addressing issues related to bribery and corruption, while also clarifying their responsibilities.
2. Policy statement
2.1 Urbanvex is dedicated to maintaining ethical and honest business practices and is focused on establishing and enforcing mechanisms that effectively prevent bribery. The organization upholds a strict zero-tolerance policy towards bribery and corrupt practices. We pledge to conduct ourselves in a professional, fair, and integrity-driven manner in all business interactions and relationships, regardless of our location within the country.
2.2 Urbanvex is dedicated to maintaining full compliance with all anti-bribery and corruption legislation in every jurisdiction in which we operate. We are governed by the laws of Ireland, the UK, and the EU, including the Bribery Act 2010, concerning our conduct both locally and internationally.
2.3 Urbanvex is aware that the consequences of bribery and corruption can include imprisonment for up to ten years and significant financial penalties. In the event that our company is found to have engaged in corrupt activities, we may face unlimited fines, exclusion from public contract tenders, and detrimental effects on our reputation. Consequently, we are committed to preventing bribery and corruption in our business operations and take our legal responsibilities with great seriousness.
3. Who is covered by the policy?
3.1 This anti-bribery policy is applicable to all individuals associated with our organization, including staff members, regardless of their employment status—be it temporary, fixed-term, or permanent—are included, specialists, external workers, interns, personnel on secondment, remote employees, temporary workers, and agency personnel, contributors who work without pay, participants in educational programs, liaisons, and patrons who provide sponsorship, the scope of this policy includes all individuals or entities connected to us, including third parties, along with our subsidiaries and their employees, irrespective of their geographical location, whether in the UK or outside it. Additionally, it applies to Trustees, Committee members, Officers, and Board members at every level.
3.2 Within the framework of this policy, the term "third-party" encompasses any individual or organization that our company engages with or collaborates alongside. This includes both current and prospective suppliers, business associates, advisors, clients, customers, distributors, agents, as well as governmental and public entities, along with their officials, advisors, politicians, representatives, and other public stakeholders.
3.3 Our company’s arrangements with third parties will be bound by clearly defined contractual terms, which incorporate specific stipulations that obligate the third party to meet minimum compliance criteria.
4. Definition of bribery
4.1 Bribery involves the act of giving, soliciting, offering, promising, receiving, agreeing to, or accepting something advantageous or valuable to motivate or influence a specific action or decision.
4.2 A bribe constitutes any form of reward, inducement, or valuable object provided to an individual to obtain a regulatory, commercial, personal, or contractual advantage.
4.3 The concept of bribery extends beyond the mere provision of a bribe. An individual who receives and accepts a bribe is also violating the law.
4.4 Employees are prohibited from engaging in any form of bribery, whether it is direct, indirect, or conducted through a third party such as an agent or distributor. Engaging in bribery is against the law. The working staff are prohibited from bribing foreign public officials in any part of the globe. Additionally, employees must refrain from accepting bribes of any kind. If there is any doubt about whether a situation involves a bribe, gift, or hospitality, employees should seek guidance from the company’s compliance manager.
5. What is and what is NOT acceptable
5.1 This segment of the policy pertains to four specific areas:
• Tokens of appreciation and cordiality.
• Grese payments.
• Donations made to political entities and their campaigns.
• Financial gifts intended for philanthropic endeavors.
5.2 Gifts and hospitality
Urbanvex acknowledges customary and suitable expressions of hospitality and goodwill, whether offered to or received from third parties, provided that the exchange of gifts adheres to the following criteria.
a. The intention behind this action is not to sway the recipient, nor to secure or reward the continuation of a business relationship or advantage, nor to serve as a direct or indirect trade for favors or benefits.
b. It adheres to the regulations set forth by local legislation.
c. It is not designed to convey that a return of kindness is anticipated.
d. It is fitting for the context, for instance, offering small tokens of appreciation during the Christmas period or as a gesture of thanks to a company that has contributed to the successful completion of a major project.
e. Cash and cash equivalents, including vouchers or gift certificates, are not included.
f. The designation is attributed to the company rather than to an individual.
g. The item is appropriate regarding its kind and value, and it is bestowed at a suitable time, mindful of the underlying reason for the gift.
h. It is offered in an open manner, as opposed to being concealed.
i. No offers or acceptances may be made to or from government officials, representatives, politicians, or political parties without the prior consent of the company’s compliance manager.
j. It does not exceed a specific excessive amount, as established by the company’s compliance manager, typically set at over £100.
k. It is not exclusively bestowed upon a prominent individual, evidently with the purpose of directly swaying their decisions.
5.3 In instances where rejecting a gift could be seen as offensive, particularly when engaging with individuals from particular religious or cultural backgrounds, the acceptance of the gift is allowed, provided it is communicated to the compliance manager for an assessment of the relevant circumstances.
5.4 Urbanvex acknowledges that the customs surrounding the exchange of business gifts differ across countries, regions, cultures, and religions, leading to varying definitions of what is deemed acceptable or unacceptable in these practices.
5.5 In accordance with best practices, it is essential to inform the compliance manager of any gifts exchanged. Furthermore, gifts from suppliers should be disclosed without exception.
5.6 The rationale for giving or receiving a gift must always be taken into consideration. Should there be any doubt, it is prudent to seek the counsel of the compliance manager.
5.7 Facilitation Payments and Kickbacks
Urbanvex maintains a firm stance against the acceptance or issuance of facilitation payments in any form. We recognize that these payments are a manifestation of bribery, designed to expedite or facilitate the actions of public officials in the context of routine governmental operations. It is acknowledged that they are often sought by lower-ranking officials to ensure or hasten the performance of specific duties or actions.
5.8 Urbanvex maintains a firm policy against the acceptance or issuance of kickbacks. It is understood that kickbacks are often given in exchange for a business advantage or favor.
5.9 Urbanvex understands that, notwithstanding our rigorous stance on facilitation payments and kickbacks, employees may find themselves in scenarios where abstaining from such payments could endanger their safety or that of their family members. In these instances, the subsequent steps are required to be taken:
a. Limit all quantities to the smallest extent feasible.
b. Inquire about obtaining a receipt that outlines both the total amount paid and the justification for the payment.
c. Generate a record pertaining to the payment.
d. It is advisable to notify your line manager regarding this incident.
5.10 Political Contributions
Urbanvex will refrain from providing donations, whether monetary, in-kind, or through any other method, to assist any political parties or candidates. We acknowledge that this decision may be viewed as an effort to secure an unfair business advantage.
5.11 Charitable Contributions
Urbanvex not only accepts but also advocates for the donation to charitable causes, which may take the form of services, expertise, time, or direct financial contributions, whether in cash or other formats. Additionally, the organization pledges to reveal all charitable donations it makes.
5.12 We will make certain that all charitable donations adhere to the legal and ethical requirements of local regulations, and that no donations are executed without the explicit consent of the compliance manager.
5.13 It is imperative for employees to be vigilant in ensuring that charitable contributions are not utilized to facilitate or disguise bribery.
6. Employee Responsibilities
6.1 Employees at Urbanvex are required to diligently read, grasp, and comply with the contents of this policy, in addition to any training or other resources concerning anti-bribery and corruption that you may be offered.
6.2 Employees who violate this policy will encounter disciplinary consequences, which may lead to termination for severe misconduct. The Managing Director and CEO holds the right to end the contractual relationship with any employee who breaches this anti-bribery policy.
6.3 In the event that you have any basis for believing or suspecting that bribery or corruption has occurred or may occur in the future, in violation of this policy, it is essential that you notify the compliance manager.
6.4 All personnel and those within our jurisdiction hold equal accountability for preventing, detecting, and reporting instances of bribery and other corrupt practices. They must ensure that they do not participate in any actions that could potentially lead to, or indicate, a contravention of this anti-bribery policy.
7. What happens if I need to raise a concern?
7.1 This part of the policy encompasses three distinct areas:
a. Guidelines for Addressing a Concern.
b. Steps to follow if you find yourself a victim of bribery or corruption.
c. Protection.
7.2 Guidelines for Addressing a Concern.
In the event that you suspect bribery or corrupt activities in relation to Urbanvex, it is important to raise your concerns promptly. If you find yourself unsure whether a certain action or behavior can be classified as bribery or corruption, you should reach out to your line manager, the compliance manager, the director, or the Head of Governance and Legal for guidance.
7.3 Urbanvex is committed to educating all employees about its whistleblowing procedures, allowing them to raise their concerns quickly and with assurance of confidentiality.
7.4 Steps to follow if you find yourself a victim of bribery or corruption.
You are required to notify your compliance manager as soon as possible if you are approached with a bribe, if you are requested to offer a bribe, if you suspect that you might soon be involved in a bribery situation, or if you have any reason to think that you are experiencing other forms of corruption.
7.5 Protection
If you choose not to accept or offer a bribe, or if you report a concern related to possible bribery or corruption, Urbanvex recognizes that you may have apprehensions about possible repercussions. Urbanvex pledges to provide support to anyone who raises concerns in good faith in accordance with this policy, regardless of whether an investigation concludes that the concerns were incorrect.
7.6 Urbanvex pledges to protect individuals from any harmful treatment resulting from their refusal to engage in bribery or other corrupt practices, as well as from any consequences arising from their reporting of concerns related to potential bribery or corruption.
7.7 Detrimental treatment involves the termination of employment, disciplinary actions, intimidation, or any negative treatment associated with the concerns expressed by the individual.
7.8 In the event that you feel you have been subjected to improper treatment as a result of voicing a concern or refusing a bribe, you are strongly encouraged to inform your line manager or the compliance manager immediately.
8. Training and communication
8.1 As part of the induction process for all new hires, Urbanvex will deliver training regarding this policy. Furthermore, employees will engage in regular training sessions that are relevant to maintaining compliance with this policy, and they will be asked to formally confirm their agreement to comply with it each year.
8.2 Urbanvex’s policy against bribery and corruption, coupled with its firm zero-tolerance position, will be shared with all suppliers, contractors, business partners, and any third parties at the commencement of business interactions and as required thereafter.
8.3 Urbanvex is committed to offering essential anti-bribery and corruption training to employees when it is determined that their comprehension of the Bribery Act needs to be strengthened. It is considered best practice for all companies to ensure that their employees receive anti-bribery training in situations where there is a likelihood of encountering bribery or corruption in their professional activities.
9. Record keeping
9.1 Urbanvex will maintain comprehensive and precise financial documentation, ensuring that suitable internal controls are established to serve as proof for all transactions conducted. We will formally document the amounts and justifications for any hospitality or gifts received and provided, recognizing that such gifts and hospitality are subject to managerial oversight.
10. Monitoring and reviewing
10.1 At Urbanvex, the compliance manager holds the responsibility of monitoring the policy’s effectiveness and will routinely assess its implementation. This role includes evaluating the policy’s appropriateness, adequacy, and efficiency.
10.2 To confirm their effectiveness in practice, internal control systems and procedures intended to prevent bribery and corruption are routinely subjected to audits.
10.3 Any necessary enhancements will be implemented at the earliest opportunity. Employees are invited to provide their insights regarding this policy, particularly if they have recommendations for its improvement. Such feedback should be directed to the compliance manager.
10.4 This policy is not a component of an employee’s contract of employment, and Urbanvex may revise it at any time to strengthen its efficacy in combating bribery and corruption.
1.1 The purpose of this anti-bribery policy is to clarify the obligations of Urbanvex and its personnel in relation to our unwavering commitment to combating bribery and corruption.
1.2 Additionally, it provides essential information and guidance to assist employees in identifying and addressing issues related to bribery and corruption, while also clarifying their responsibilities.
2. Policy statement
2.1 Urbanvex is dedicated to maintaining ethical and honest business practices and is focused on establishing and enforcing mechanisms that effectively prevent bribery. The organization upholds a strict zero-tolerance policy towards bribery and corrupt practices. We pledge to conduct ourselves in a professional, fair, and integrity-driven manner in all business interactions and relationships, regardless of our location within the country.
2.2 Urbanvex is dedicated to maintaining full compliance with all anti-bribery and corruption legislation in every jurisdiction in which we operate. We are governed by the laws of Ireland, the UK, and the EU, including the Bribery Act 2010, concerning our conduct both locally and internationally.
2.3 Urbanvex is aware that the consequences of bribery and corruption can include imprisonment for up to ten years and significant financial penalties. In the event that our company is found to have engaged in corrupt activities, we may face unlimited fines, exclusion from public contract tenders, and detrimental effects on our reputation. Consequently, we are committed to preventing bribery and corruption in our business operations and take our legal responsibilities with great seriousness.
3. Who is covered by the policy?
3.1 This anti-bribery policy is applicable to all individuals associated with our organization, including staff members, regardless of their employment status—be it temporary, fixed-term, or permanent—are included, specialists, external workers, interns, personnel on secondment, remote employees, temporary workers, and agency personnel, contributors who work without pay, participants in educational programs, liaisons, and patrons who provide sponsorship, the scope of this policy includes all individuals or entities connected to us, including third parties, along with our subsidiaries and their employees, irrespective of their geographical location, whether in the UK or outside it. Additionally, it applies to Trustees, Committee members, Officers, and Board members at every level.
3.2 Within the framework of this policy, the term "third-party" encompasses any individual or organization that our company engages with or collaborates alongside. This includes both current and prospective suppliers, business associates, advisors, clients, customers, distributors, agents, as well as governmental and public entities, along with their officials, advisors, politicians, representatives, and other public stakeholders.
3.3 Our company’s arrangements with third parties will be bound by clearly defined contractual terms, which incorporate specific stipulations that obligate the third party to meet minimum compliance criteria.
4. Definition of bribery
4.1 Bribery involves the act of giving, soliciting, offering, promising, receiving, agreeing to, or accepting something advantageous or valuable to motivate or influence a specific action or decision.
4.2 A bribe constitutes any form of reward, inducement, or valuable object provided to an individual to obtain a regulatory, commercial, personal, or contractual advantage.
4.3 The concept of bribery extends beyond the mere provision of a bribe. An individual who receives and accepts a bribe is also violating the law.
4.4 Employees are prohibited from engaging in any form of bribery, whether it is direct, indirect, or conducted through a third party such as an agent or distributor. Engaging in bribery is against the law. The working staff are prohibited from bribing foreign public officials in any part of the globe. Additionally, employees must refrain from accepting bribes of any kind. If there is any doubt about whether a situation involves a bribe, gift, or hospitality, employees should seek guidance from the company’s compliance manager.
5. What is and what is NOT acceptable
5.1 This segment of the policy pertains to four specific areas:
• Tokens of appreciation and cordiality.
• Grese payments.
• Donations made to political entities and their campaigns.
• Financial gifts intended for philanthropic endeavors.
5.2 Gifts and hospitality
Urbanvex acknowledges customary and suitable expressions of hospitality and goodwill, whether offered to or received from third parties, provided that the exchange of gifts adheres to the following criteria.
a. The intention behind this action is not to sway the recipient, nor to secure or reward the continuation of a business relationship or advantage, nor to serve as a direct or indirect trade for favors or benefits.
b. It adheres to the regulations set forth by local legislation.
c. It is not designed to convey that a return of kindness is anticipated.
d. It is fitting for the context, for instance, offering small tokens of appreciation during the Christmas period or as a gesture of thanks to a company that has contributed to the successful completion of a major project.
e. Cash and cash equivalents, including vouchers or gift certificates, are not included.
f. The designation is attributed to the company rather than to an individual.
g. The item is appropriate regarding its kind and value, and it is bestowed at a suitable time, mindful of the underlying reason for the gift.
h. It is offered in an open manner, as opposed to being concealed.
i. No offers or acceptances may be made to or from government officials, representatives, politicians, or political parties without the prior consent of the company’s compliance manager.
j. It does not exceed a specific excessive amount, as established by the company’s compliance manager, typically set at over £100.
k. It is not exclusively bestowed upon a prominent individual, evidently with the purpose of directly swaying their decisions.
5.3 In instances where rejecting a gift could be seen as offensive, particularly when engaging with individuals from particular religious or cultural backgrounds, the acceptance of the gift is allowed, provided it is communicated to the compliance manager for an assessment of the relevant circumstances.
5.4 Urbanvex acknowledges that the customs surrounding the exchange of business gifts differ across countries, regions, cultures, and religions, leading to varying definitions of what is deemed acceptable or unacceptable in these practices.
5.5 In accordance with best practices, it is essential to inform the compliance manager of any gifts exchanged. Furthermore, gifts from suppliers should be disclosed without exception.
5.6 The rationale for giving or receiving a gift must always be taken into consideration. Should there be any doubt, it is prudent to seek the counsel of the compliance manager.
5.7 Facilitation Payments and Kickbacks
Urbanvex maintains a firm stance against the acceptance or issuance of facilitation payments in any form. We recognize that these payments are a manifestation of bribery, designed to expedite or facilitate the actions of public officials in the context of routine governmental operations. It is acknowledged that they are often sought by lower-ranking officials to ensure or hasten the performance of specific duties or actions.
5.8 Urbanvex maintains a firm policy against the acceptance or issuance of kickbacks. It is understood that kickbacks are often given in exchange for a business advantage or favor.
5.9 Urbanvex understands that, notwithstanding our rigorous stance on facilitation payments and kickbacks, employees may find themselves in scenarios where abstaining from such payments could endanger their safety or that of their family members. In these instances, the subsequent steps are required to be taken:
a. Limit all quantities to the smallest extent feasible.
b. Inquire about obtaining a receipt that outlines both the total amount paid and the justification for the payment.
c. Generate a record pertaining to the payment.
d. It is advisable to notify your line manager regarding this incident.
5.10 Political Contributions
Urbanvex will refrain from providing donations, whether monetary, in-kind, or through any other method, to assist any political parties or candidates. We acknowledge that this decision may be viewed as an effort to secure an unfair business advantage.
5.11 Charitable Contributions
Urbanvex not only accepts but also advocates for the donation to charitable causes, which may take the form of services, expertise, time, or direct financial contributions, whether in cash or other formats. Additionally, the organization pledges to reveal all charitable donations it makes.
5.12 We will make certain that all charitable donations adhere to the legal and ethical requirements of local regulations, and that no donations are executed without the explicit consent of the compliance manager.
5.13 It is imperative for employees to be vigilant in ensuring that charitable contributions are not utilized to facilitate or disguise bribery.
6. Employee Responsibilities
6.1 Employees at Urbanvex are required to diligently read, grasp, and comply with the contents of this policy, in addition to any training or other resources concerning anti-bribery and corruption that you may be offered.
6.2 Employees who violate this policy will encounter disciplinary consequences, which may lead to termination for severe misconduct. The Managing Director and CEO holds the right to end the contractual relationship with any employee who breaches this anti-bribery policy.
6.3 In the event that you have any basis for believing or suspecting that bribery or corruption has occurred or may occur in the future, in violation of this policy, it is essential that you notify the compliance manager.
6.4 All personnel and those within our jurisdiction hold equal accountability for preventing, detecting, and reporting instances of bribery and other corrupt practices. They must ensure that they do not participate in any actions that could potentially lead to, or indicate, a contravention of this anti-bribery policy.
7. What happens if I need to raise a concern?
7.1 This part of the policy encompasses three distinct areas:
a. Guidelines for Addressing a Concern.
b. Steps to follow if you find yourself a victim of bribery or corruption.
c. Protection.
7.2 Guidelines for Addressing a Concern.
In the event that you suspect bribery or corrupt activities in relation to Urbanvex, it is important to raise your concerns promptly. If you find yourself unsure whether a certain action or behavior can be classified as bribery or corruption, you should reach out to your line manager, the compliance manager, the director, or the Head of Governance and Legal for guidance.
7.3 Urbanvex is committed to educating all employees about its whistleblowing procedures, allowing them to raise their concerns quickly and with assurance of confidentiality.
7.4 Steps to follow if you find yourself a victim of bribery or corruption.
You are required to notify your compliance manager as soon as possible if you are approached with a bribe, if you are requested to offer a bribe, if you suspect that you might soon be involved in a bribery situation, or if you have any reason to think that you are experiencing other forms of corruption.
7.5 Protection
If you choose not to accept or offer a bribe, or if you report a concern related to possible bribery or corruption, Urbanvex recognizes that you may have apprehensions about possible repercussions. Urbanvex pledges to provide support to anyone who raises concerns in good faith in accordance with this policy, regardless of whether an investigation concludes that the concerns were incorrect.
7.6 Urbanvex pledges to protect individuals from any harmful treatment resulting from their refusal to engage in bribery or other corrupt practices, as well as from any consequences arising from their reporting of concerns related to potential bribery or corruption.
7.7 Detrimental treatment involves the termination of employment, disciplinary actions, intimidation, or any negative treatment associated with the concerns expressed by the individual.
7.8 In the event that you feel you have been subjected to improper treatment as a result of voicing a concern or refusing a bribe, you are strongly encouraged to inform your line manager or the compliance manager immediately.
8. Training and communication
8.1 As part of the induction process for all new hires, Urbanvex will deliver training regarding this policy. Furthermore, employees will engage in regular training sessions that are relevant to maintaining compliance with this policy, and they will be asked to formally confirm their agreement to comply with it each year.
8.2 Urbanvex’s policy against bribery and corruption, coupled with its firm zero-tolerance position, will be shared with all suppliers, contractors, business partners, and any third parties at the commencement of business interactions and as required thereafter.
8.3 Urbanvex is committed to offering essential anti-bribery and corruption training to employees when it is determined that their comprehension of the Bribery Act needs to be strengthened. It is considered best practice for all companies to ensure that their employees receive anti-bribery training in situations where there is a likelihood of encountering bribery or corruption in their professional activities.
9. Record keeping
9.1 Urbanvex will maintain comprehensive and precise financial documentation, ensuring that suitable internal controls are established to serve as proof for all transactions conducted. We will formally document the amounts and justifications for any hospitality or gifts received and provided, recognizing that such gifts and hospitality are subject to managerial oversight.
10. Monitoring and reviewing
10.1 At Urbanvex, the compliance manager holds the responsibility of monitoring the policy’s effectiveness and will routinely assess its implementation. This role includes evaluating the policy’s appropriateness, adequacy, and efficiency.
10.2 To confirm their effectiveness in practice, internal control systems and procedures intended to prevent bribery and corruption are routinely subjected to audits.
10.3 Any necessary enhancements will be implemented at the earliest opportunity. Employees are invited to provide their insights regarding this policy, particularly if they have recommendations for its improvement. Such feedback should be directed to the compliance manager.
10.4 This policy is not a component of an employee’s contract of employment, and Urbanvex may revise it at any time to strengthen its efficacy in combating bribery and corruption.