Anti-Corruption & Bribery Policy
About this policy
This policy applies to Green Park Pharma UK Ltd and its subsidiaries (‘We’, ‘Us’, the Company). It is our policy to conduct all of our business honestly and ethically. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated immediately. This policy does not form part of any employee's contract of employment, and we may amend it at any time. It will be reviewed regularly.
Who must comply with this policy?
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, agents, contractors, external consultants, third-party representatives, and business partners.
What is bribery?
Bribe means a financial or other inducement or reward for an action which is illegal, unethical, a breach of trust, or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract, or any other advantage or benefit. Bribery includes offering, promising, giving, accepting, or seeking a bribe. All forms of bribery are strictly prohibited. If you are unsure whether a particular act constitutes bribery or have any queries about this policy, please raise it with your line manager or the Group Finance Director.
Specifically, you must not:Give or offer any payment, gift, hospitality, or other benefit in the expectation that a business or personal advantage will be received in return or to reward any business received;
Accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business or personal advantage for them or anyone else;
Give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure. You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
Gifts & Hospitality
This policy does not prohibit giving or accepting reasonable and appropriate hospitality for legitimate business purposes such as building relationships, maintaining our image or reputation, or marketing our products and services. A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, is not within a business context, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process). Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers) or be given in secret. Gifts must be given in our name, not your name. As a general rule, gifts must not exceed £25 in value. Promotional gifts of low value, such as branded stationery, may be given to or accepted by existing customers, suppliers, and business partners. The ABPI’s Code of Practice tightly binds the company to the Pharmaceutical Industry (2024), and all gifts and hospitality must fall within these guidelines (subject to the maximum amount for gifts specified above). The ABPI’s code of practice can be found by following this link: ABPI Code of Practice 2024
Record-Keeping
It would be best if you informed your direct supervisor about any hospitality or gifts you give or receive and maintain a written record of these. This record should be submitted to the supervisor, who will review and retain it for transparency. Additionally, all expenses related to hospitality, gifts, or payments to third parties must be recorded accurately and submitted in line with our expenses policy, clearly stating the reason for each expenditure. Ensure all dealings with third parties, including suppliers and customers, are documented accurately and entirely in our official records. No accounts should be maintained 'off-book' to avoid improper payments.
How to raise a concern
If you are offered a bribe or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your line manager or the Group Finance Director or report it in accordance with our Whistleblowing Policy as soon as possible.
Last updated: 21 October 2024