McTear Williams & Wood Limited

Anti-Corruption and Bribery Act Policy and Register

Policy statement

It is the policy of McTear Williams & Wood Limited ("the firm") to conduct business in an honest and open manner.  As such the firm takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships and implementing and enforcing effective systems to counteract bribery.  Our business culture is one where bribery is never acceptance.

Purpose

The firm will uphold all laws relevant to counter bribery and corruption in accordance with The Bribery Act 2010.  The objective of this document is to:

  • Support the firm's stated policy that our business culture is one where bribery is never acceptable;
  • Record the receipt and payment of any significant gift and/or hospitality; and
  • Act as evidence of appropriate procedures to prevent bribery or corruption.

This document derives from guidance provided by the Ministry of Justice ("MOJ") which can be found at https://www.gov.uk/government/publications/bribery-act-2010-guidance

Gifts, payments and hospitality

The firm accepts that its directors and staff may accept normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

  • All individual one off gifts with a value of £100+ or one off hospitality with a value of £500+ (given or received) must be recorded on the Bribery Act Register.
  • All gifts with a cumulative value over £500 within a year or hospitality with a cumulative value over £5,000 (given or received) must also be recorded on the Bribery Act Register.

Whistle-blowing

Our firm is committed to carrying on its business fairly, openly and honestly.  Our business culture is one where bribery is never acceptable.

Everyone in the firm, whatever their level, is allowed full access to the Bribery Act Register within normal business hours.  In the event that they become aware of any reward, gift or hospitality being received or provided by anyone in the firm in excess of the levels above they may check this record to see that it is duly authorised.

If they identify any reward, gift or hospitality outside the above levels that has not been disclosed and authorised they should, as long as that person is not connected to the matter, report in the first instance to their senior manager.  If their senior manage is involved, they should report to the Company Secretary.

If the recipient or provider is a Director of the firm they should report to the Company Secretary.

All Directors of the firm undertake that they will not take any disciplinary action or otherwise discriminate against anyone who raise a genuine concern about matters relating to the Bribery Act, whether the concern proves to be valid or unfounded and no matter what position in the organisation the recipient or provider holds.

The firm will investigate the circumstances, giving the individual concerned an opportunity to explain the transaction and give reasons for not seeking appropriate authority.  Any willful failure to obtain authority for a qualifying transaction or series of transactions may be treated as a disciplinary matter, even if the investigation finds that the transaction was one that could have been authorised.  If the failure is significant enough to suggest that there may be an element of wrongdoing or bribery it may comprise gross misconduct and could result in immediate dismissal.


Last updated: 18 November 2019


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