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Bribery

The offering; promising, giving, accepting or soliciting of any advantage as an action which is illegal or a breach of trust.

It is unacceptable 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 form a third party that you know or suspect is offered with the exception that it will obtain a business advantage for them;
    • Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
    • Retaliate against or threaten a person who has refused to commit a bribery office or who has raised concerns under this policy;
    • Engage in activity in breach of this policy.

Objective of this Policy

This policy provides a coherent and consistent framework to enable PCIAW® employees to understand and implement arrangements; enabling compliance. In conjunction with related policies and key documents, it will also enable employees to identify and effectively report a potential breach.

We require that all staff, including those permanently employed, temporary agency staff and contractors to:

    • Act honestly and with integrity at all times and to safeguard the organisation’s resources for which they are responsible;
    • Comply with the spirit; as well as the letter, of the laws and regulations of all jurisdictions in which PCIAW® operates, in respect of the lawful and responsible conduct of activities.

Scope of this Policy

This policy applies to all of PCIAW® activities. For partners; joint ventures and suppliers, we will seek to promote the adoption of policies consistent with the principles set out in this policy.

Within PCIAW®; the responsibility to control the risk of bribery occurring resides at all levels of the Company. It does not reset solely within assurance functions; but in all business units and corporate functions.

This policy covers all staff including all levels and grades, those permanently employed, temporary agency staff, contractors, agents, members (including independent members), volunteers and consultants.

PCIAW® Commitment to Action

PCIAW® commits to:

    • Setting out a clear anti-bribery policy and keeping it up to date;
    • Ensure a systematic approach to risk assessment of the nature and extent of bribery risk associated within the construction industry and global market;
    • Making all employees aware of their responsibilities to adhere strictly to this policy at all times;
    • Training all employees so that they can recognise and avoid the use of bribery by themselves and others;
    • Encouraging its employees to be vigilant and to report any suspicions of bribery; providing them with suitable channels of communication and ensuring sensitive information is treated appropriately in a confidential manner to a designated senior manager;
    • Ensure that our suppliers; agents, intermediaries and fellow participants in joint ventures are fully aware of their responsibility for and are committed to complying with our anti-bribery policy;
    • Taking firms and vigorous action against any individual(s) involved in bribery;
    • Provide information to all employees; to report breaches and suspected breaches of this policy;
    • Include appropriate clauses in contracts to prevent bribery.

Facilitation Payments

PCIAW® prohibits ‘facilitation’ or ‘grease’ payments as these are bribes and illegal. Facilitation payments are commonly small payments made to secure or speed up routine actions, usually by public officials, such as issuing permits, immigration controls, providing services or releasing goods held in customs. It is also our policy that we work to ensure that our agents and other intermediaries; joint ventures and consortia, contractors and suppliers do not make facilitation payments on our behalf. If you have doubts about a payment and suspect that it might be considered a facilitation payment only make the payment if the official or third party can provide a formal receipt or written confirmation of its legality. If practicable, obtain a senior management/ legal approval for the payment or consult the Company Secretary. If the demand is accompanied by immediate threat or physical harm then put safety first, make the payment and report immediately to senior management/legal department, the circumstances and amount of the payment made ‘under duress’.

Gifts, Hospitality and Expenses

PCIAW® prohibit the offer or receipt of gifts, hospitality or expenses whenever they could affect or be perceived to affect the outcome of business transactions and are not reasonable, proportionate and bona fide. Whether any corporate hospitality is improper is judged by reference to what a reasonable person in the UK would expect. For example; an invitation to foreign or British clients to attend a rugby match at Twickenham designed to enhance relationships between the parties is certainly not improper. The 2010 Bribery Act and this policy does not prevent corporate hospitality. It requires a sensible approach to hospitality to be used to ensure that promotional business expenditure that seeks to improve the image, better presents services or establishes cordial relations is reasonable and proportionate.