Anti-Bribery & Corruption Policy

1. Purpose and top-level commitment

PCIAW Ltd has zero tolerance for bribery and corruption. We conduct business fairly, honestly and transparently and comply with the Bribery Act 2010 and applicable anti-bribery laws in every country in which we operate.

The Board and senior management are responsible for setting the tone, providing proportionate prevention procedures and ensuring that commercial pressure never justifies bribery. This policy supports the six principles in the Ministry of Justice guidance: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.

Bribery includes offering, promising or giving an advantage to induce improper conduct; requesting, agreeing to receive or accepting an advantage for improper conduct; bribing a foreign public official; and, for a commercial organisation, failing to prevent bribery by an associated person where the statutory conditions are met.

2. Scope and individual responsibility

This policy applies to directors, officers, employees, workers, temporary staff, volunteers, consultants, contractors, agents and any other person performing services for or on behalf of PCIAW. We expect members, sponsors, exhibitors, suppliers, partners and joint-venture participants to follow equivalent standards when dealing with PCIAW or representing us.

Everyone covered must:

• act honestly, protect PCIAW resources and avoid conflicts of interest;
• understand the bribery risks relevant to their role, market and transaction;
• complete required checks, approvals and training;
• keep accurate records; and
• raise a concern promptly where conduct appears improper.

3. Prohibited conduct

You must not directly or indirectly:

• offer, promise or give money, a gift, hospitality, employment, sponsorship, discount, membership benefit, donation or other advantage to obtain or reward improper business or regulatory treatment;
• request, agree to receive or accept an advantage in return for improper performance;
• offer an advantage to a public official to influence them in their official capacity;
• make a facilitation or “grease” payment to speed up a routine action;
• use an agent, supplier, member, consultant or other intermediary to do anything PCIAW could not lawfully do itself;
• conceal a payment, create a false description, maintain an off-book account or split a transaction to avoid approval;
• retaliate against someone who refuses to participate in bribery or raises a concern in good faith; or
• ignore warning signs or knowingly permit conduct that breaches this policy.

If a payment is demanded under an immediate threat to health or safety, put personal safety first, make no more payment than necessary, obtain a receipt if safely possible and report the facts and amount to senior management as soon as it is safe.

4. Gifts, hospitality, expenses, sponsorship and donations

Reasonable and proportionate hospitality intended to build legitimate business relationships is not automatically prohibited. It becomes unacceptable where it could influence—or reasonably appear to influence—a decision, tender, award, membership outcome, procurement process or public official.

Gifts and hospitality must be bona fide, lawful, infrequent, proportionate to the relationship and local market, openly provided in PCIAW’s name, accurately recorded and approved under the applicable internal procedure. Cash and cash equivalents are prohibited. Particular care and advance approval are required for public officials, tender participants, award judging, active negotiations and higher-risk jurisdictions.

Charitable or political donations, sponsorship, complimentary membership, discounts and event benefits must never be used as a disguised bribe. Political contributions may not be made on PCIAW’s behalf without lawful authority and Board approval.

5. Risk assessment, third parties, due diligence and records

PCIAW assesses bribery risk proportionately, considering geography, sector, transaction value, public-sector contact, use of intermediaries, unusual payment requests and the nature of the relationship. Enhanced checks and senior approval are required where risk is higher.

Before appointing or paying an agent, consultant, introducer, supplier or other associated person, PCIAW may verify identity, ownership, competence, reputation, sanctions exposure, conflicts, business rationale and payment arrangements. Contracts should contain proportionate anti-bribery obligations, audit or information rights and termination rights.

Payments must match genuine, documented services, go to an appropriate account in the contracting party’s name and be supported by accurate invoices and approvals. Secret commissions, unexplained success fees, excessive hospitality, offshore payments without commercial justification and requests to bypass controls are warning signs that must be escalated.

6. Raising concerns, protection and investigation

Report any request, suspicion, attempted bribe, conflict or control failure promptly to senior management or email info@pciaw.org with “Confidential anti-bribery concern” in the subject. Provide facts, dates, people involved and available evidence; do not investigate covertly or place yourself at risk.

Reports are handled as confidentially as reasonably possible, shared only with those who need to assess or investigate them, and documented appropriately. PCIAW prohibits retaliation against anyone who refuses a bribe or raises a concern honestly, even if the concern is not substantiated.

We will investigate proportionately, preserve relevant records, take legal or professional advice where needed and report to law enforcement or a regulator where required. A breach may result in disciplinary action, termination of a contract or membership consequences, recovery of loss and referral to authorities.

7. Communication, training, monitoring and review

This policy is communicated to relevant people and made available to members, suppliers and partners. Role-appropriate training is provided where exposure warrants it, and managers are expected to reinforce the controls in day-to-day decisions.

PCIAW monitors the effectiveness of its procedures through periodic risk review, due-diligence checks, approval and payment records, reported concerns and lessons from incidents. The policy is reviewed at least annually and when law, organisational structure, markets or risk materially change.

Questions about a proposed gift, hospitality item, payment or relationship should be raised before committing PCIAW. No person is criticised for delaying a transaction in order to obtain a compliance decision.