Anti-Corruption and Anti-Bribery Policy
The following outlines Ekco’s Anti-Corruption and Anti-Bribery policy.
• It is our policy to conduct all our business in an honest, integrity and in an ethical manner;
• We take a zero-tolerance approach to any corrupt practices;
• We comply with all relevant laws in the territories that we operate, including;
- Irish Criminal Justice (Corruption Offences) Act 2018
- UK Bribery Act 2010
- Wet op de economische delicten (Economic Offences Act)
- Anti-Corruption Commission Act 2009 (Act 694)
• No personnel or Third Party will suffer demotion, penalty, or other adverse consequence for refusing to pay or receive bribes, or participate in other illicit behaviour, even if such refusal may result in the company losing business.
This policy should be read together with the Employee Handbook and other relevant policies and guidelines.
Scope
This policy applies to all Ekco employees, including directors, permanent & part-time staff, contractors, suppliers, and agents.
Definitions
| Term | Definition |
|---|---|
| Bribery & Corruption |
Any action which would be considered as an offence within the applicable laws. |
| Conflict of Interest |
When a person’s own interest either influence, have the potential to influence, or are perceived to influence decision-making. |
| Corporate Gift | Something given from one organisation to another, with the appointed representatives of each organisation giving and accepting the gift. Corporate gifts may also be promotional items given out equally to the general public at events, trade shows and exhibitions as a part of building the company’s brand. |
| Donations & Sponsorship |
Charitable contributions and sponsorship payments made to support the community. Examples include sponsorship of educational events, supporting NGOs, and other social causes. |
| Facilitation Payment |
A payment or other provision made personally to an individual in control of a process or decision. It is given to secure or expedite a routine or administrative duty or function to which the payer has legal or other entitlement. |
| Financial Incentives |
Row Cash or financial benefit or assistance from any third party with whom the Company may have a business connection. |
| Hospitality | The considerate care of guests, which may include refreshments, accommodation and entertainment at a restaurant, hotel, club, resort, convention, concert, sporting event or other venue such as company offices, with or without the personal presence of the host. Provision of travel may also be included. |
| Whistleblowing | Disclosure by a person Whistleblowing to those within the company in a position of authority and/or appointed to receive such disclosures, or a government authority, or the media, of attempted, suspected, and actual malpractice. |
Policy Guidance
| Policy Area | Guidance |
|---|---|
| Hospitality & Gifts |
Hospitality & gifts offered by Ekco must: • Be approved & recorded in advance (where appropriate); • Be modest & appropriate; • Not frequently be offered to the same client or contact; • Be submitted with supported receipts in line with the expenses policy Hospitality & gifts received by Ekco should: • Be disclosed to the company in advance (where appropriate); • Be modest & appropriate; • Not frequently be received from the same client or contact You must always avoid accepting any hospitality or gift that does not meet the above criteria. If unsure about the appropriateness of a particular situation, seek guidance from your line manager or a member of the People Operations team. |
| Financial Incentives |
It is prohibited to solicit or accept any cash or financial benefit from any third party with whom the Company may have a business connection or with whom you deal with in relation to the Company’s business. |
| Facilitation Payments |
It is not acceptable to make a facilitation payment to any government or other official or any third party to speed up an official procedure or to receive an advantage through payment where ordinarily no such payment is officially required. |
| Donations and Sponsorships | The company does not make any donations to any political party. All Company donations to register charities must be approve in advance in line with company policies and made only via official channels. |
| Conflicts of Interest |
It is not acceptable to have any dealing with a third-party with whom the Company has a business connection whereby you, a friend or relative might gain an advantage in return for some advantage for that third party. Where a potential conflict of interest may exist, for the avoidance of doubt, this should be reported to your line manager or HR in advance of the business taking place. |
Non-Compliance
It is the responsibility of all Ekco employees, directors, permanent & part-time staff, contractors, suppliers,
and agents to comply with this policy. Breaches of the standards required by this policy will be addressed by the company disciplinary procedure. Any breach will be treated seriously and could constitute gross misconduct resulting in dismissal.
Raising Concerns
If you have any questions about this policy or any concerns about corruption or bribery within the Ekco organisation or supply chain, please contact the People Operations Team.
Exceptions
There are no exceptions to this policy statement.
Last Updated: December 2023
