Our position
Rothian does not tolerate bribery or corruption in any form, anywhere we work. We would rather lose business than win it improperly. This policy reflects the UK Bribery Act 2010, which applies to our conduct worldwide, and the anti-corruption laws of every country we operate in, including the United Arab Emirates and India.
Who it applies to
Directors, employees, associates, subcontractors, agents and anyone else acting on Rothian’s behalf.
What is prohibited
You must not:
- offer, promise or give anything of value to anyone to induce or reward improper performance of their role, or to obtain or keep business or an advantage;
- request, agree to receive or accept anything of value in return for improper performance;
- bribe a public official, anywhere, to influence them in their official capacity;
- make facilitation payments — small unofficial payments to speed up routine government actions — even where they are customary; or
- use a third party, a family member or a charitable donation to do any of these things indirectly.
The only exception is a payment demanded under threat to someone’s safety or liberty. Make it, get safe, and report it to a director immediately.
Gifts and hospitality
Reasonable, proportionate hospitality and modest gifts are a normal part of business. They become a problem when they could influence, or appear to influence, a decision. Before giving or accepting any gift or hospitality, ask whether it would be comfortable to see it reported publicly.
- Gifts or hospitality worth more than £100, given or received, must be approved in advance by a director and recorded in the register.
- Cash, or cash equivalents such as vouchers, must never be given or accepted.
- Nothing may be given to or accepted from anyone involved in a live tender or procurement decision with us.
- Gifts and hospitality for public officials require prior approval regardless of value.
Conflicts of interest
Declare any personal, financial or family interest that could conflict with your duties to Rothian or a client before it can affect a decision. Associates must declare work for a client’s competitor or supplier where it is relevant to an engagement.
Third parties
We carry out proportionate due diligence on partners, agents and subcontractors who act for us, include anti-bribery obligations in their contracts, and pay only for legitimate services at fair market rates, into accounts in the name of the provider.
Records
All payments, expenses, gifts and hospitality must be accurately recorded. No off-book accounts, and no records that disguise the true nature of a payment.
Raising concerns
If you are asked for a bribe, offered one, or suspect bribery, report it straight away to a director or through our whistleblowing policy. No one will suffer for refusing to pay a bribe or for raising a genuine concern, even if it costs us business.
Consequences
Breaching this policy is gross misconduct for employees and grounds for immediate termination for associates and suppliers, and may be a criminal offence. We will cooperate fully with the authorities.
Review
A director is responsible for this policy. We assess bribery risk annually, train our people at induction and annually, and review the policy at least once a year.