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;
o Irish Criminal Justice (Corruption Offences) Act 2018
o UK Bribery Act 2010
o Wet op de economische delicten (Economic Offences Act)
o Malaysian Anti-Corruption Commission Act 2009 (Act 694)
o Prevention and Combating of Corrupt Activities Act, 2004 (South Africa)
• 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, agents, and any other third parties associated with Ekco.
Definitions
| Term | Definition |
|---|---|
| Bribery & Corruption |
Any act that constitutes an offence under applicable laws related to bribery, corruption, or fraudulent conduct. |
| Conflict of Interest |
A situation where an individual’s personal interests influence, have the potential to influence, or are perceived to influence their decision-making within the company. |
| Corporate Gift | An item given from one organisation to another, typically through their appointed representatives. Corporate gifts may also include promotional items distributed to the general public at events, trade shows, or exhibitions as part of brand-building activities. |
| Donations & Sponsorship |
Charitable contributions or sponsorship payments made to support community initiatives, such as educational events, non-governmental organisations (NGOs), or social causes. |
| Facilitation Payment |
A payment or provision made personally to an individual who controls a process or decision, intended to secure or expedite a routine or administrative function to which the payer is legally entitled. |
| Financial Incentives |
Cash or other financial benefits received from any third party with which the company has a business relationship. |
| Hospitality | The provision of considerate care to guests, including refreshments, accommodation, or entertainment at locations such as restaurants, hotels, clubs, resorts, conventions, concerts, sporting events, or company offices, with or without the host’s presence. Travel arrangements may also be included. |
| Whistleblowing | The act of reporting, by an individual within the company, suspected or actual malpractice to those in a position of authority, appointed company representatives, a government authority, or the media. |
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 the People Operations team in advance of the business taking place. You should avoid placing yourself in situations where (directly or indirectly) you can personally gain from, or be influenced by, a personal or business relationship or interest in the course of performing your duties for Ekco. |
| Government and Other Officials |
Caution must be taken when dealing with public officials in connection with contracts between Ekco and any governmental or official body, whether in the UK, Ireland, Netherlands, Malaysia, South Africa, or other regions. Any expenses associated with interactions involving an official body should be cleared in advance with the relevant public entity. For example, sponsoring a conference fee for an official’s participation in an industry event must be coordinated directly with the official’s public body, not just with the individual. |
| Tax Evasion | Ekco is committed to acting professionally, fairly, and with integrity in all our business dealings and relationships wherever we operate, and to implementing and enforcing effective systems to counter the facilitation of tax evasion. Ekco will uphold all laws relevant to countering tax evasion in all jurisdictions where we operate, including: • UK Criminal Finances Act 2017 • Irish Taxes Consolidation Act 1997 (as amended) • Wet op de economische delicten (Economic Offences Act) – Netherlands • Malaysian Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 • Tax Administration Act, 2011 (South Africa) |
Non-Compliance
It is the responsibility of all Ekco employees, directors, permanent and part-time staff, contractors, suppliers, and agents to fully comply with this policy. Breaches of the standards required by this policy, including failure to report known violations, will be addressed through the company’s disciplinary procedures. Any breach will be treated with the utmost seriousness and could constitute gross misconduct, potentially leading to immediate dismissal, termination of contracts, and legal action, where appropriate.
Employees, contractors, and agents must report any suspected or actual breaches of this policy to their line manager or through the designated whistleblowing channels. Ekco is committed to ensuring that no one faces retaliation for reporting concerns in good faith.
Where appropriate, Ekco may also report suspected criminal activities to the relevant authorities for further investigation and potential prosecution.
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: November 2024
