TMDP is committed to implementing and enforcing effective systems to counter bribery. Therefore, it is TMDP's policy to conduct all aspects of its business in an honest and ethical manner at all times.
This policy applies to all individuals working for a TMDP business, including anyone providing services to TMDP such as consultants, or contractors.
The aim of this policy is to help TMDP to act in accordance with the Bribery Act 2010, maintain the highest possible standards of business practice, and advise individuals of TMDP’s ‘zero-tolerance’ to bribery.
Under UK law (UK Bribery Act 2010), bribery and corruption is punishable for individuals by up to ten years imprisonment. If a TMDP company is found to have taken part in the corruption or lacks adequate procedures to prevent Bribery, it could face an unlimited fine and be excluded from tendering for Government contracts.
This policy applies to all permanent and/or temporary staff employed by TMDP, and any contractors, consultants or other persons acting under or on behalf of TMDP.
A TMDP company will not:
A TMDP company will:
Employees must not:
This policy does not prohibit giving and receiving promotional gifts of low value, or normal and appropriate hospitality; providing they have been approved by the TMDP board or are organised by the main Group.
The acceptance of corporate hospitality must be transparent; all invitations must be reported to the company before an employee accepts any invitation. The following areas are exempt while attending conferences, seminars, sponsored by third parties.
Failing to observe Company policy may lead to disciplinary action in accordance with TMDP’s Disciplinary Policy.
In the event of a breach of the policy by other organisations, or individuals, TMDP will take appropriate action.
The policy will be monitored on an on-going basis to ensure that it addresses issues effectively.
The following will be monitored:
Monitoring of the policy is essential to assess how effective TMDP has been to establish control of its obligations.
Bribe is a financial or other advantage offered or given to anyone to persuade them to or reward them for performing their duties improperly, or, with the intention of influencing them in the performance of their duties.
Hospitality is the practice of being hospitable, this includes the reception and entertainment of guests/visitors.
Kickbacks or facilitation payments are typically small payments made in return for a business favour or advantage.
This policy will be reviewed and, if necessary, revised in the light of legislative or organisational changes. Improvements will be made by learning from experience and the use of an established annual review.
Should any amendments, revisions, or updates be made to this policy it is the responsibility of TMDP senior management to see that all relevant employees receive notice.