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Anti-Bribery and Anti-Corruption Policy

1. Policy Statement and Scope

Quiss Technology Plc is committed to uphold the highest standards of professional integrity, in all its business dealings and relationships. Our reputation with our clients, suppliers and other partners is underpinned by our ethical behaviour, transparency, and honesty. Quiss prohibits all forms of bribery and corruption.

Quiss is bound by and is compliant with, all laws related to anti-bribery and corruption including the Bribery Act 2010 in relation to our conduct within the UK and abroad. We are committed to implementing and enforcing systems that ensure bribery and corruption are prevented, aligning with our zero-tolerance approach.

Quiss recognises that acts of bribery and corruption are a criminal offence. They are punishable by up to 10 years of imprisonment for individuals and if the Company, is discovered to have taken part in corruption, it will face an unlimited fine, be excluded from tendering for public contracts, resulting in detrimental damage to the Quiss brand and reputation. We therefore take our legal responsibilities very seriously.

This policy exists to:

  • set out the expectations of the Company and those working for it, in observing and upholding its zero-tolerance position on bribery and corruption
  • act as a source of information and guidance for all individuals working for Quiss, on how to recognise and deal with bribery and corruption issues
  • act as a clear statement to all our business partners and clients

This policy applies to all employees of Quiss, regardless of seniority, location and contract status (i.e. permanent, fixed term or temporary). It also extends to individuals working on our behalf, for example, agency staff or contractors or other individuals representing Quiss. All employees and associated individuals are responsible for maintaining the highest standards of business conduct and are expected to behave honestly and with integrity.

Any breaches to this policy, by an employee or an associated individual will face disciplinary action, which could result in dismissal for gross misconduct (termination of contract). It may also become a criminal matter for the individual.

2. What is Bribery?

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage, so to induce or influence an action or decision. Bribes can take many forms: from money, gifts, loans, fees, hospitality, services, vouchers, discounts, to the awarding of a contract or any other advantage or benefit. This behaviour is dishonest, illegal and a breach of trust.

Accordingly, employees and associated individuals are prohibited to engage in any form of bribery or corruption, whether it be directly, passively or through a third party. If they are uncertain about whether something is a bribe or a gift or an act of hospitality, they must seek further advice from HR or the Finance team.

3. Entertainment, Hospitality and Gifts

Entertainment and hospitality such as a meal, invitations to events, functions, or other social gatherings, in connection with matters related to our business or as a simple token of appreciation and gratitude, are acceptable, provided that:

  • they fall within reasonable bounds of value and are limited, in occurrence
  • the intention behind the meal / invitation is considered

On occasion, packaged gifts or vouchers may be received by Quiss employees or associated individuals. Should this occur, these gifts (irrespective of its value) must be declared and handed in to the Finance team, who will record the items for audit purposes. These items will be subject to scrutiny and review by the Directors.

4. Unacceptable behaviour or conduct

It is not acceptable for any employee or associated individuals to:

  • give, promise to give, or offer, a payment, gift or hospitality, with the expectation or hope that either a personal or business advantage will be received; or to reward either a personal or business advantage
  • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a decision or process
  • accept payment from a third party that the employee/associated individual knows or suspects, is offered with the expectation that it will render either a personal or business advantage for them
  • accept a gift or hospitality from a third party if an employee/associated individual knows or suspects that it is offered or provided with an expectation that either a personal or business advantage will be provided by Quiss in return
  • accept a gift or hospitality from a third party who is tendering for a contract to be awarded by Quiss either on its own or jointly with other parties
  • turn a blind eye to any of the above
  • threaten or retaliate against another employee or associated individual who has refused to commit a bribery offence or who has raised concerns under this policy
  • engage in any activity that might lead to a breach of this policy

5. Donations

Quiss do not make any contributions to political parties.

6. Individual Responsibility

Employees and associated individuals must ensure that they have read and understood, all the information contained within this policy and similarly with any training or other anti-bribery and corruption information they are given.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of everyone working for (or representing) Quiss. All employees and associated individuals are prohibited to engage in any activity that might lead to, or suggest, a breach of this policy.

Employees or associated individuals should use the Quiss Whistle-Blowing Policy or notify HR, as soon as possible, if they believe or suspect that a conflict with this policy has occurred or may occur in the future. If they are unsure whether a particular act constitutes bribery or corruption, they should contact the HR or Finance team.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. It may also lead to a criminal investigation.

Quiss reserves the right to terminate its contractual relationship with associated individuals or third parties, if they breach this policy.

7. How to raise a concern

If an employee or associated individual suspects that there is an instance of bribery or that corrupt activities may be occurring, they are encouraged to raise their concerns at as early a stage as possible, either through the Whistle Blowing Policy or by discussing their concerns with HR.

Quiss will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.

If employees or associated individuals are uncertain about whether something is either a bribe, a gift or an act of hospitality, they must seek further advice from the Finance Team or HR.

8. Protection

If an employee or associated individual has refused to accept or offer a bribe, or they have reported a concern relating to potential act(s) of bribery or corruption, Quiss understands that an employee/associated individual may feel worried about potential repercussions and will support anyone who raises concerns in good faith under this policy, even if an investigation finds that they were mistaken.

Quiss will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe, refusing to engage in other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

If you have reason to believe you have been subjected to unjust treatment as a result of raising a concern or refusing to accept a bribe, you should inform your line manager or HR.

9. Awareness and Training

Quiss will provide online training for all new starters on how to adhere to this policy, as part of the induction process. Existing employees will also receive annual online training. All staff will also be asked to formally accept that they will comply with this policy.

Our zero-tolerance approach to bribery and corruption will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations and our policy will be available on our website.

10. Record Keeping

The Head of Finance will keep detailed and accurate financial records and will have appropriate internal controls in place as evidence for all payments made and for any gifts declared and received by employees. The Company will declare and keep a written record of the amount and reason for hospitality, or for gifts accepted and given, and understands that gifts and acts of hospitality are subject to Directorial review.

11. Monitoring and Reviewing

The Director of Operations has the overall responsibility for monitoring the effectiveness of this policy and will ensure it is reviewed on an annual basis, so that it remains suitable for combatting bribery and corruption.

This policy does not form part of an employee’s contact of employment and may be reviewed and amended at any time. It will be available to all new starters at Quiss and to all existing staff through the Quiss intranet.

This policy may be reviewed and amended at any time.