1. Introduction
TUS Ltd is committed to conducting business with the highest standards of ethical behavior and integrity. This Anti-Bribery Policy establishes our commitment to preventing bribery and corruption in all aspects of our operations. This policy applies to all employees, contractors, agents, consultants, and any other individuals or entities acting on behalf of TUS Ltd.
2. Prohibition of Bribery
2.1 Bribery is strictly prohibited in all forms. No employee or representative of TUS Ltd shall offer, promise, give, request, or accept bribes, whether directly or indirectly, to or from any person, including but not limited to customers, suppliers, government officials, or any other party.
2.2 Bribery includes the offering, giving, receiving, or soliciting of any undue advantage, whether in the form of cash, gifts, hospitality, loans, services, favours, or any other benefit that is intended to influence or improperly reward business decisions or actions.
3. Compliance with Applicable Laws
3.1 TUS Ltd and its employees shall comply with all applicable anti-bribery laws and regulations, including the UK Bribery Act 2010 and any other relevant local laws in the jurisdictions where we operate.
3.2 Compliance with this policy is mandatory, and any breach of anti-bribery laws or this policy may result in disciplinary action, including termination of employment or contract and legal consequences.
4. Gifts, Hospitality, and Entertainment
4.1 TUS Ltd acknowledges that the provision of reasonable and proportionate gifts, hospitality, and entertainment can be a legitimate part of business relationships. However, these activities must be conducted transparently and in compliance with applicable laws and regulations.
4.2 Employees and representatives must exercise caution and judgment when giving or accepting gifts, hospitality, or entertainment, ensuring that they are reasonable, proportionate, and consistent with customary business practices. Gifts should not be offered or accepted if they could be perceived as influencing or compromising business decisions.
4.3 Any gifts, hospitality, or entertainment given or received must be properly recorded in accordance with TUS Ltd's internal controls and reporting procedures.
5. Facilitation Payments
5.1 TUS Ltd strictly prohibits facilitation payments, also known as "grease payments." Facilitation payments are small payments or bribes made to government officials or individuals to expedite routine government actions or services that they are already obligated to perform.
5.2 No employee or representative shall make or accept facilitation payments, regardless of the circumstances or local customs.
6. Third Parties
6.1 TUS Ltd expects its employees and representatives to conduct appropriate due diligence when engaging and managing relationships with third parties, including suppliers, agents, intermediaries, consultants, and business partners, to mitigate the risk of bribery and corruption.
6.2 Agreements with third parties should include anti-bribery provisions, and appropriate anti-bribery clauses should be incorporated into contracts and agreements.
7. Reporting and Whistleblowing
7.1 TUS Ltd encourages all employees and representatives to report any concerns or suspicions of bribery or corruption promptly. This includes any knowledge of potential or actual violations of this policy, irrespective of the individuals involved.
7.2 TUS Ltd provides channels for confidential and anonymous reporting, such as a designated whistleblowing hotline or an established reporting mechanism. Reports will be treated with strict confidentiality, and appropriate measures will be taken to protect the identity of the reporter.
8. Training and Awareness
8.1 TUS Ltd is committed to providing training and raising awareness among its employees and representatives on anti-bribery policies, procedures, and legal requirements. Training programs will be conducted regularly to ensure that employees understand their responsibilities and the consequences of non-compliance.
8.2 Training sessions may cover topics such as identifying bribery risks, recognizing red flags, reporting procedures, and the importance of maintaining ethical business practices.
9. Compliance Monitoring and Review
9.1 TUS Ltd will monitor and review its anti-bribery controls and procedures regularly to ensure their effectiveness and compliance with applicable laws and regulations.
9.2 Internal audits and assessments may be conducted periodically to assess the implementation and adherence to this policy.
10. Reporting Violations and Non-Retaliation
10.1 Any employee or representative who becomes aware of a potential or actual violation of this policy must report it promptly to their supervisor, manager, or the designated reporting channel.
10.2 TUS Ltd prohibits any form of retaliation against individuals who report suspected or actual violations of this policy in good faith. Retaliation is a serious violation and will result in disciplinary action.
11. Disciplinary Measures
11.1 Violations of this policy will not be tolerated. Any employee or representative found to have engaged in bribery, corruption, or related misconduct will be subject to disciplinary action, which may include termination of employment, contract termination, legal action, or other appropriate measures.
12. Communication and Implementation
12.1 TUS Ltd is committed to communicating and implementing this anti-bribery policy throughout the organization.
12.2 This policy will be made available to all employees and representatives, and regular communication and training programs will be conducted to ensure understanding and compliance.
12.3 Updates or revisions to this policy will be communicated to all relevant individuals to ensure ongoing adherence.
13. Contact Information
13.1 . If you have any questions, concerns, or need to report a suspected violation of this policy, please contact the designated compliance officer or the Ethics Hotline.
Compliance Officer:
Name: Kerryn Allan
Email: [email protected]
Phone: 03301170120
Ethics Hotline:
Phone: 01913410213