Anti-Bribery & Corruption Policy

Version 1.2 · Effective 1 November 2023

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Introduction

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COPE is committed to the highest level of ethical standards and to a zero-tolerance approach to bribery and corruption. Our systems for preventing bribery include communicating awareness to employees, assessing risk, providing clear reporting mechanisms, investigating concerns rigorously and taking enforcement action where necessary.

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Scope

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This policy applies to all permanent and temporary employees, and to “associated persons” — including directors, contractors, consultants, agents, suppliers and sponsors.

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Definitions

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Bribery is the offering, promising, giving, solicitation, or the receipt or agreement to receive, any financial or other advantage for an improper purpose. Corruption is the abuse of entrusted power for private gain. This policy prohibits bribery intended to gain a commercial advantage, secure personal gain, or induce the improper performance of a function or activity.

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Legal context

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This policy is framed with reference to the Bribery Act 2010. Violations can carry personal liability for individuals and potentially unlimited fines for the organisation.

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Our provisions

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• We comply with all applicable anti-bribery legislation and act with honesty and integrity.

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• Business gifts require Director approval and must be given openly and in COPE’s name.

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• Facilitation payments and secret gift-giving are prohibited.

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• Normal hospitality, ceremonial gifts of token value and recognised fast-track processes are permitted where customary and proportionate.

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Responsibilities and reporting

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All personnel must work to prevent bribery and report any suspected violation in line with our Whistleblowing Policy. COPE is committed to protecting those who report concerns in good faith from any detrimental treatment.

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Record keeping and sanctions

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All financial documents must be prepared and maintained with strict accuracy and completeness. Breaches of this policy are disciplinary offences that may result in summary dismissal or termination of contract. The policy is communicated to employees and business partners and is subject to periodic review and amendment.

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COPE Occupational Health Services Ltd is registered in England & Wales (company no. 03425211). Registered office: 5 Castle Quay, Nottingham, NG7 1FW.