Anti-Bribery Policy

Introduction

The company values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. It aims therefore to limit its exposure to bribery by:

  • Setting out a clear anti-bribery policy.
  • Establishing and implementing anti-bribery procedures as appropriate.
  • Communicating this policy and any relevant procedures to employees and to others who will perform services for the Company via purchase orders and / or crew briefings.
  • Monitoring and reviewing the risks and the effectiveness of any anti-bribery procedures that are in place.

This policy has been created to inform employees how they should act regarding the provision and/or receipt of hospitality and/or gifts whilst working for Cue.

If you do not comply with this policy, you could face disciplinary action from Cue.
If you are not directly employed by Cue, your placement/secondment/other arrangement could be terminated.

Cue’s Policy

The company prohibits the offering, giving, solicitation or acceptance of any bribe (whether cash or other inducement):

  •  to or from any person or company (wherever they are situated and whether they are a public official/body/private person/company).
  • by any individual employee, agent, other person, or body acting on behalf of the company.
  •  to gain any commercial, contractual, or regulatory advantage for the company in a way that is unethical.
  • to gain any personal advantage (pecuniary or otherwise) for the individual or anyone connected with the individual.

This policy is not meant to prohibit normal and appropriate hospitality or the giving of a gift, providing they are proportionate.

Inevitably, decisions as to what is acceptable may not always be easy. If you are in any doubt as to whether a potential act constitutes bribery, the matter should be referred to the HR Director before proceeding. If the HR Director is not available or you could be perceived as rude if you do not immediately respond, it is advised that you accept the gift and then return it later if it is deemed by the HR Director as a bribe.

Who this Policy Covers

This policy covers everyone who works for Cue or with Cue. That includes full-time, part-time, temporary, or interim roles working at any level of the organisation. It also covers anyone working on behalf of Cue as a contractor, supplier, or consultant.

Employees’ Responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees, and the company is committed to:

  • Encouraging employees to be vigilant and to report any suspicion of bribery.
    official/body/private person/company).
  • Providing employees with suitable channels of communication and ensuring that sensitive information is treated appropriately.
  • Investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution.
  • Taking disciplinary action against any individual(s) involved in bribery.

Any suspicion of bribery should be reported in confidence to the HR Director, who has overall responsibility for bribery prevention.

Protocol if Bribery Occurs

If you are offered or have provided any gift or hospitality (whether accepted or not) that is disproportionate, unusual, or you believe constitutes a bribe – you must complete a Hospitality/Gift Declaration Form which can be found here: Q:\Policies and Procedures\Bribery Policy and hand it into the HR Department.

You should return any unreasonably generous gift(s) quickly, with a letter politely explaining our policy and that Cue cannot accept it. If the gift cannot be returned, such as perishables, your line manager will seek advice from the HR Department regarding this.

You should only accept or provide hospitality when you can show that it is in Cue’s interest. That might be helping with a key business aim or to build relationships for a clear business goal, but it should not lead to potential concerns for your reputation or that of Cue.

Transparency is essential, especially if you are dealing with suppliers – your decisions should never be seen to generate influence. If you remain unsure about whether you should offer or accept a gift, hospitality, or other benefits, you must seek advice from the HR Department.

There is a document detailing the process that Cue will follow if a bribe occurs, which can be found here: Q:\Policies and Procedures\Bribery Policy\Management Information Process for Reporting Risks and Issues Relating to Anti-Bribery.

What is Acceptable?

  • You can accept any hospitality that is reasonable in the circumstances.
  • Gifts that are trivial, inexpensive, or reasonable and proportionate e.g., low value promotional gifts under the value of £25 (calendars / diaries), conventional personal gifts (flowers), low value gifts to be shared by your team (sweets / cakes).
  • You may attend commercially sponsored conferences or courses at the sponsor’s expense, except where it could be seen to potentially compromise our purchasing decisions. To attend these events, you need the agreement of the Managing Director or HR Director before you accept.
  • Special occasions (one-off events to celebrate a big achievement). Refreshments or gifts can be provided if they are justified by the Finance Director or the Managing Director and meet a cost limit of up to £50.

What is Unacceptable?

  • A holiday abroad.
  • Use of a company or private house, flat or hotel suite.
  • High value gifts or experiences.
  • Any official off-site hospitality must not exceed the hospitality you have received.
  • Charitable or political contributions.
  • Sponsorship.
  • Facilitation payments.

Legal Guidance

The penalties for bribery offences in the United Kingdom are governed by the Bribery Act 2010. It must be stated here that legal information can change, and it is essential to consult the most recent legal sources or seek advice from legal professionals for the latest information.

The Bribery Act 2010 outlines the following penalties for bribery offences: :

  • Individuals found guilty of bribery can face a maximum prison sentence of up to 10 years. Individuals may also face fines; the amount of the fine is at the discretion of the court.
  • Companies can be liable for failing to prevent bribery and may face an unlimited fine if they are found guilty.
For more information, please visit Bribery Act 2010 | The Law Society.

How we keep Records

Cue will keep detailed, accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. The Finance Department has a documented approval process for significant expenditure through Pleo cards and expense floats.

Cue has an Anti-Bribery Risk Assessment in place that will be monitored and updated in accordance with the latest government guidance.

When an employee completes a Declaration Form, the HR Department will enter this information into a Hospitality/Gift Log to keep track of patterns.

Changes

Cue Media Ltd may change this policy from time to time by updating this page 

Version No. 1
Last Updated – 11/01/24

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