It is our policy to conduct our business in an honest and ethical manner. 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.
Our Anti-Corruption and Bribery Policy applies to everyone working for us, with us or on our behalf in any capacity, including employees, freelancers, agency workers, interns, work-experience students, agents, contractors, external consultants, our distributed publishers, third-party representatives and museum partners.
Breach of this policy by an employee may result in disciplinary action under our Disciplinary Procedure, up to and including dismissal for gross misconduct.
What is bribery?
A bribe is a financial or other inducement or reward for an action that 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.
Specifically, you must not:
- Give or offer any payment, gift, hospitality or
other benefit in the expectation that a business advantage will be received in return, or to reward any business received; - Accept any such offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else; and/or
- 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.
All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, please discuss it with our Head of HR.
Gifts and hospitality
This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or promoting our business and products.
Occasional gifts of nominal value, presented out of courtesy (such as promotional gifts of low value that may be given to or accepted from existing customers, suppliers, business partners, authors and other content providers) are usually acceptable. However, you must notify your Line Manager of any gift and failure to do so may lead to disciplinary action under our Disciplinary Procedure. Gifts of cash or cash equivalent (such as vouchers) cannot be accepted, nor should gifts be given in secret. Gifts must be given and received in the name of the company, not in your name.
You may not give or accept hospitality or gifts which do not conform to good business practice, which may influence you or which may be seen by others as likely to influence you in your work.
Record-keeping
You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our Expenses Policy and record the reason for expenditure.
All accounts, invoices, and other records relating to dealings with third parties, including suppliers and customers, should be prepared with strict accuracy and completeness. Accounts must not be kept ‘off-book’ to facilitate or conceal improper payments.
How to raise a concern
If you are offered a bribe or think that you may have been offered a bribe, you must refuse it and report it immediately to your Head of Department. You will not suffer any detrimental treatment for refusing to take part in bribery and corruption, provided that you report it in accordance with this policy. That is the case even if your suspicions turn out to be mistaken. If you are in any doubt about whether to report something, please report it and we will investigate it.
If you have a question on any aspect of our Anti-Corruption & Bribery Policy please ask our Head of HR.
Last updated: 07/03/19
