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DAM Anti-Corruption Policy

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  1. Introduction

Definite Article Media Limited (hereinafter referred to as “the Company”) is committed to conducting its business in an honest and ethical manner. We have zero tolerance for corruption in any form and adhere to all applicable anti-corruption laws, including the UK Bribery Act 2010. This policy outlines our stance on anti-corruption and provides guidelines for gifts and entertainment.

  1. Purpose

The purpose of this policy is to:

– Establish a clear and consistent framework for identifying and addressing corruption risks.

– Provide guidance on acceptable business conduct, particularly concerning gifts and entertainment.

– Ensure compliance with legal and regulatory requirements.

  1. Scope

This policy applies to all employees, officers, directors, agents, contractors, and third-party representatives of the Company (collectively referred to as “staff”).

  1. Definition of Corruption

Corruption refers to the abuse of entrusted power for private gain. This includes, but is not limited to, bribery, kickbacks, extortion, embezzlement, and fraud.

  1. Prohibited Conduct

Staff must not:

– Offer, give, solicit, or accept any bribe or improper payment, whether in cash or any other form.

– Engage in any activity that could be perceived as corrupt or unethical.

  1. Gifts and Entertainment Guidelines

6.1 General Principles

Gifts and entertainment can build goodwill and strengthen working relationships, but they can also create conflicts of interest and potential for corruption. Staff must exercise caution and ensure that any gift or entertainment is:

– Modest in value.

– Given or received in good faith.

– Not intended to influence business decisions.

6.2 Acceptable Gifts and Entertainment

Staff may accept or offer gifts and entertainment that meet the following criteria:

– The value does not exceed £50.

– It is customary and appropriate in the business context.

– It is not given with the expectation of receiving something in return.

– It does not create a sense of obligation or dependency.

6.3 Prohibited Gifts and Entertainment

Staff must not accept or offer:

– Cash or cash equivalents (e.g., vouchers, gift cards).

– Gifts or entertainment that could influence or appear to influence a business decision.

– Lavish or extravagant gifts or entertainment.

– Gifts or entertainment during a bidding process or negotiation.

6.4 Reporting and Approval

Staff must report any gift or entertainment received or offered that exceeds the £50 threshold to their line manager. In cases of uncertainty about the appropriateness of a gift or entertainment, staff should seek guidance from their line manager or management.

  1. Responsibilities

7.1 Employees

All employees are responsible for:

– Understanding and complying with this policy.

– Reporting any suspected or actual corruption or policy violations.

7.2 Managers

Managers are responsible for:

– Ensuring their teams understand and comply with this policy.

– Monitoring and reviewing any gifts or entertainment reported by their staff.

– Providing guidance on this policy.

7.3 Compliance Officer

The Compliance Officer is responsible for:

– Overseeing the implementation and enforcement of this policy.

– Providing training and resources to staff on anti-corruption.

– Investigating any reported violations of this policy.

  1. Training and Communication

The Company will provide regular training to all staff on anti-corruption laws and this policy. This policy will be communicated to all staff and made available on the Company’s intranet.

  1. Monitoring and Review

The Company will regularly monitor compliance with this policy and review its effectiveness. The policy will be updated as necessary to reflect changes in legislation or business practices.

  1. Reporting Violations

Staff should report any suspected or actual corruption or policy violations to the line manager or management. All reports will be treated confidentially and investigated promptly.

  1. Consequences of Non-Compliance

Non-compliance with this policy may result in disciplinary action, up to and including termination of employment. The Company may also report any illegal activities to the relevant authorities.

  1. Conclusion

Definite Article Media Limited is committed to maintaining the highest standards of integrity and transparency in all its business dealings. By adhering to this policy, we can help ensure a fair and ethical business environment.

For any questions or further information, please contact the management.

Approval and Effective Date

This policy is approved by the Board of Directors and is effective as of 1 February 2018

v.7 Reviewed 1 February 2024

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