The British Iranian Chamber of Commerce
Anti-Corruption and Bribery Policy

  1. ABOUT THIS POLICY
    1. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero- tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.
    2. We will uphold all laws relevant to countering bribery and corruption. However, we remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad.
    3. Any directly engaged contractor may have their contract terminated for gross misconduct.
    4. This policy does not form part of any contractor's contract of engagement and we may amend it at any time. It will be reviewed regularly.
  2. WHO MUST COMPLY WITH THIS POLICY?
    1. This policy applies to all persons working for us or on our behalf in any capacity, including, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.
  3. WHAT IS BRIBERY?
    1. Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
    2. Bribery includes offering, promising, giving, accepting or seeking a bribe.
    3. All forms of bribery are strictly prohibited. Specifically, you must not:
      1. 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;
      2. give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;
      3. accept a payment, gift or hospitality from a third party that you know or suspect is offered with the expectation that it we will provide a business advantage for them or anyone else in return;
      4. accept hospitality from a third party that is unduly lavish or extravagant under the circumstances;
      5. offer or accept a gift to or from government officials or representatives, or politicians or political parties without the prior approval of the Chairman
      6. threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; or
      7. engage in any other activity that might lead to a breach of this policy.
  4. FACILITATION PAYMENTS AND KICKBACKS
    1. We do not make, and will not accept, facilitation payments or "kickbacks" of any kind.
    2. Facilitation payments, also known as "back-handers" or "grease payments", are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official).
    3. Kickbacks are typically payments made in return for a business favour or advantage.
    4. You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the Chairman.
  5. GIFTS AND HOSPITALITY
    1. This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
    2. A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).
    3. Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.
    4. Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.
  6. RECORD-KEEPING
      We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties. You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.
  7. YOUR RESPONSIBILITIES
    1. You must ensure that you read, understand and comply with this policy.
    2. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
    3. You must notify the Chairman as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. "Red flags" that may indicate bribery or corruption are set out in Clause 9.
  8. HOW TO RAISE A CONCERN
    1. If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify the Chairman as soon as possible.
    2. If you are unsure about whether a particular act constitutes bribery or corruption, raise it with the Chairman.
  9. POTENTIAL RISK SCENARIOS: "RED FLAGS"
    1. The following is a list of possible red flags that may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
    2. If you encounter any of these red flags while working for us, you must report them promptly to the Chairman if:
      1. you become aware that a third party engages in, or has been accused of engaging in, improper business practices;
      2. you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials;
      3. a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
      4. a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
      5. a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
      6. a third party requests an unexpected additional fee or commission to "facilitate" a service;
      7. a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
      8. a third party requests that a payment is made to "overlook" potential legal violations;
      9. a third party requests that you provide employment or some other advantage to a friend or relative;
      10. you receive an invoice from a third party that appears to be non-standard or customised;
      11. a third party insists on the use of side letters or refuses to put terms agreed in writing;
      12. you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
      13. a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;
      14. you are offered an unusually generous gift or offered lavish hospitality by a third party.