Supply Chain Solutions No.33 – Employee Bribery

Organisations engaged in direct and indirect procurement, there is always a chance an employee will engage in some form of inappropriate behavior that is not in the interest to the business. Businesses should address bribery as a potential risk and as such, require all employees to sign a Bribery Code of Conduct  yearly as reminder of what is acceptable and what is unacceptable when a gift is presented.

Like all regulations, the bribery code of conduct is to deter the minority not the majority of employees.  As such, this document should not be seen as tool to undermine employees trust, but as a tool to reduce risk and to give employees who have information an avenue to report the information anonymously.

Bribery Code of Conduct

Below is an example of a Bribery Code of Conduct that could be present to employees (XXXXCOMPANY should be replaced by your company name);

Dear Employee,

The bribery code is a document that is reviewed by XXXX COMPANY on a regular basis to ensure the code remains current within our operating environment and the expectations of our stakeholders.

Please read the below code and seek guidance when questions arise. As documented, it is your responsibility to raise questions, make appropriate disclosures and bring potential problems to the Company’s attention.

Violation of the bribery code is a serious matter that could subject you or XXXX COMPANY to legal liability. 

Bribery is the misuse of power for private profit, or the misuse of entrusted power for private gain. Bribery is the offer, promise, or payment of cash, gifts, or even excessive entertainment, or an inducement of any kind offered or given to a person in a position of trust to influence that person’s views or conduct or to obtain an improper advantage.

Bribery can take many forms, including the provision or acceptance of:

  1. Cash payments;
  2. Phony jobs or “consulting” relationships;
  3. Kickbacks or commission;
  4. Contributions or sponsorship;
  5. Social benefits; or
  6. Gifts, travel, hospitality, and reimbursement of expenses.

If you are offered or receive a gift from a supplier, you must follow the rules below:

  1. The gift must be given to you at a business address (XXXX COMPANY office or supplier factory). You are not allowed to accept gifts at your home.
  2. The value of the gift should be less than US$60, or you could easily afford to buy the gift yourself:

  i.e.

  • Fruit baskets, chocolates, cakes and food hampers
  • Promotional items such as diaries, key rings or mouse mats
  • Lunch or dinner (all food and drink to be consumed on the occasion)
  1. The gift must not influence your business judgment.
  2. Any gift not listed in point (c) above must be registered with your HR department. This includes being invited to a supplier’s corporate entertainment event.
  • You are not allowed to accept cash gifts or cash alternatives (red envelopes or gift vouchers).
  • The practice of suppliers sponsoring company events is unacceptable.  No funds or gifts are allowed to be received for annual parties or outings.
  • Remember, generally gifts should be something that you could easily afford yourself and would not influence your business judgment.

Breaches of the Code must be reported immediately to your supervisor and/or you’re local

Human Resource department who will then notify XXXX COMPANY senior management.

However, if for some reason you do not feel comfortable reporting the breach internally, you have the right to bypass the line management structure and take your concerns directly to the General Manager or Company owners of the Company using the following email address whisleblower@XXXXCOMPANY.com

** The above infomation should be used on as a guideline and may vary regionally, further information https://www.gov.uk/government/publications/bribery-act-2010-guidance.

ID Global Concepts are experts in supply chain management. We add value to your supply chain through consultancy or management contract to ensure the business has the best practice systems that are the right fit for your business, customer and meet your value expectations.

If you would like to learn, please email us at info@idgc.co or visit our website www.idgc.co

 

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