Anti bribery policy

1. Overview

It is HOS policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and are committed to acting professionally, fairly and with integrity in all our relationships wherever we operate and to implementing and enforcing effective systems to counter bribery.
We will uphold all laws relevant to countering bribery and corruption. We remain bound by the laws of the UK, including the Bribery Act 2010.
The purpose of this policy is to:

  •  set out our responsibilities, and of those working for us, in observing and upholding our position on bribery; and
  • provide information and guidance to employees on how to deal with bribery issues.
    In this policy, third party means any individual or organisation you come into contact with during the course of your work for HOS.

2. What is bribery?

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. The Bribery Act contains three types of bribery:

  • bribing another person;
  • accepting a bribe; and
  • bribing a foreign official.

3. Employee responsibilities

You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for HOS. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify the Director of Finance & Corporate Performance as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a tenant or a landlord were to offer you a gift which could be perceived as gaining them an advantage with HOS.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal.

4. How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage with the Director of Finance & Corporate Performance, in accordance with HOS’s whistleblowing procedure. If you are unsure whether a particular act constitutes bribery, or if you have any other queries, these should be raised with the Director of Finance & Corporate Performance.

If your concern involves the Director of Finance & Corporate Performance, you should contact the Ombudsman. If your concern regards the Ombudsman, you should contact the Chair of the Audit and Risk Assurance Committee (sueharvey@campbelltickell.com).

5. What to do if you are a victim of bribery

It is important that you tell the Director of Finance & Corporate Performance as soon as possible if you are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

6. Protection

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
HOS are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.

7. Hospitality & Gifts

This policy does not prohibit some normal and appropriate hospitality (given and received) to or from third parties, provided that this is done in accordance with HOS’s Financial Procedures.
All employees must declare any gifts or hospitality that has been offered or accepted and it must be recorded on THO’s gifts and hospitality register which is saved in the e-Library. New entries to the register will be provided to each Audit and Risk Assurance Committee meeting.