1. Policy statement
Alterium and its Group of Companies, made up of Alterium Limited (ZA021336) Fleximize Limited (ZA021338), Fleximize Capital Limited (ZA244436) & Fleximize Services Limited (ZA046956), hereinafter referred to as “Fleximize”, “we” or “us”.
Fleximize is committed to high standards of ethical behaviour and takes a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships and will implement and enforce effective systems to counter bribery and corruption.
Fleximize will uphold all laws relevant to our business to counter bribery and corruption and we remain bound by the laws of the UK, including the Bribery Act 2010.
Bribery and corruption are punishable for individuals by up to ten years’ imprisonment and if we are found to have taken part in corruption we could face an unlimited fine and damage to our reputation. We therefore take our legal responsibilities very seriously.
The purpose of this policy is to publicly communicate to third parties our position on bribery and corruption. Our employees should refer to our internal policies.
In this policy, third party means any individual or organisation that comes into contact with us, and includes actual and potential clients, customers, introducers, brokers, suppliers, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
2. Who is covered by the policy?
This policy applies to:
- Fleximize’s customers and potential customers
- Any third parties Fleximize authorises to act on its behalf such as introducers, brokers, agents and/or advisers
- Fleximize’s suppliers, government and public bodies, including their advisors, representatives and officials, politicians and political parties
Where we engage with third parties, we will undertake appropriate steps to ensure that they comply with the principles set out in this policy.
A copy of this policy is available on our website.
3. What is bribery and corruption?
Corruption is the misuse of office or power for private gain.
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
4. What is not acceptable?
We do not (nor do we procure someone) to:
- Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
- Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure;
- Accept payment from a third party that we know or suspect is offered with the expectation that it will obtain a business advantage for them;
- Accept a gift or hospitality from a third party if we know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
- Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
- Engage in any activity that might lead to a breach of this policy.
5. Facilitation payments and kickbacks
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind.
Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.
Kickbacks are typically payments made in return for a business favour or advantage.
We avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices.
7. How to raise a concern
Third parties are encouraged to raise concerns with us about any issue or suspicion of malpractice at the earliest possible stage. Any concerns or issues should be referred to the Compliance Director: firstname.lastname@example.org
8. Monitoring and review
We will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness.