1. Purpose
MRL® Public Sector Consultants Ltd (“MRL”) is committed to conducting its operations with the highest standards of integrity and transparency. This policy outlines MRL’s position on preventing bribery and corruption and ensuring compliance with applicable laws, including the UK Bribery Act 2010 and relevant international standards.
2. Scope
This policy applies to all employees, directors, officers, temporary workers, contractors, consultants, agents, and any third parties acting on behalf of MRL, in the UK and internationally.
3. Policy Statement
MRL has a zero-tolerance approach to bribery and corruption. The company prohibits:
- Offering, giving, soliciting, or accepting bribes or improper payments.
- Any activity that could be interpreted as seeking to influence a decision unlawfully.
- Facilitation payments intended to expedite routine governmental actions.
Bribery and corruption, whether carried out directly or through third parties, are strictly prohibited and will result in disciplinary action, up to and including dismissal and potential legal consequences.
4. Gifts, Hospitality and Entertainment
MRL permits the exchange of gifts and hospitality only when they are:
- Reasonable, proportionate, and infrequent.
- Not given to gain any unfair business advantage.
- In compliance with MRL’s internal approval and reporting procedures.
Extravagant or suspicious gifts or hospitality are not permitted and must be declined and reported.
5. Dealings with Third Parties
MRL requires due diligence on all third parties, including clients, suppliers, subcontractors, and partners. Third parties must agree to comply with this policy and uphold MRL’s values of ethical conduct.
All contractual agreements must include anti-bribery and corruption clauses.
6. Financial Controls and Record Keeping
All transactions must be:
- Fully and accurately recorded in MRL’s financial systems.
- Supported by appropriate documentation.
- Subject to regular internal and external audits.
False, misleading, or incomplete records are strictly prohibited.
7. Roles and Responsibilities
- Employees must comply with this policy and report any concerns.
- Managers are responsible for promoting awareness and monitoring compliance.
- Compliance Officer (or designated director) is responsible for investigating reports and overseeing training and policy enforcement.
8. Reporting and Whistleblowing
MRL encourages employees and stakeholders to report any suspected bribery or corruption. Concerns can be reported to:
- A line manager
- The Compliance Officer
- [Anonymous hotline or whistleblowing channel, if applicable]
Reports will be treated confidentially. MRL prohibits retaliation against individuals who raise concerns in good faith.
9. Training and Communication
All MRL employees must undergo periodic anti-bribery and anti-corruption training. New hires will receive this training as part of their induction.
Regular communications and refresher sessions will be conducted to ensure ongoing awareness.
10. Policy Review
This policy will be reviewed annually or when significant changes occur in business operations or legislation. Revisions will be approved by senior management.
11. Consequences of Breach
Violations of this policy may result in:
- Disciplinary action up to dismissal
- Termination of contracts with third parties
- Referral to law enforcement agencies