Anti-Bribery Policy

Last updated 25/01/2022

1. Purpose
Crystal Clear Translation (CCT)’s policy is to conduct its work in a manner that is ethical and transparent. CCT has a zero-tolerance approach to bribery in all areas of work and outreach, and is committed to ensuring that its employees act professionally, fairly, and with integrity in all situations. This approach is to ensure that the company benefits from and maintains a valued and trusted reputation, as well as donor, partner, and beneficiary confidence.

2. Principles
CCT is committed to enforcing measures and systems to counter and prevent bribery.

3. Scope
This policy extends to all individuals within the company, including trustees, senior managers, employees (whether permanent, fixed term or temporary), volunteers and interns, consultants, partners and any other person or organisation providing services to CCT, whether paid or unpaid. All employees will made aware of this policy as part of their finance induction. They will be asked to sign that have read, understood and agree to abide by its content. All other persons associated with the organisation will be informed of this policy through any contractual arrangements they have.

4. Definitions and Terms
The UK Bribery Act of 2010 defines bribery as ‘giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so’.

5. Implementation
Any individual suspected of
• offering, promising or giving a bribe
• requesting, agreeing to receive or accepting a bribe, or
• bribing a public official

will be subject to investigation under the company’s disciplinary policy and if found guilty, will be dismissed for gross misconduct. Any contractor or partner found to have
offered or accepted a bribe will have their contract terminated immediately, all business dealings will cease, financial compensation will be sought, and the incident(s) will be reported to the authorities as required by the Act.

If any individual is confronted with a request to make or receive a bribe, they are expected to present a copy of or explain the company’s Anti-Bribery Policy and must not agree to the bribe in any circumstances.

Gifts and Hospitality
 This policy does not entirely prohibit the giving or receiving of gifts, but the practice is generally discouraged outside of special occasions or events. Any gifts given or received must be under GBP 20.00 or equivalent.
It is possible that gifts and/or hospitality may amount to bribery; therefore, any gifts given or received must not be done so with the intention of persuading or encouraging anyone to act inappropriately or to perform duties outside of their normal obligations. All gifts or promises of giving gifts will be appropriately documented and reviewed so as to adhere to company policy and avoid instances or allegations of bribery.

Facilitation Payments and ‘Kickbacks’
CCT does not make and will not accept facilitation payments or ‘kickbacks’ of any kind.
Facilitation payments are defined as ‘payments to induce officials to perform routine functions they are otherwise obligated to perform’ by the Bribery Act. ‘Kickbacks’ are typically payments made in return for a business favour or advantage, and any other improper services received. All employees must avoid any activity that may lead to, or suggest, that a facilitation payment or kickback will be made or accepted on behalf of CCT.

Donations
CCT does not make or accept donations or equivalent contributions to or from to political parties.

Financial Systems
CCT will keep financial records and ensure appropriate internal controls are in place to ensure there is an evidence trail for any payments made to third parties as an anti-corruption measure.
All expense claims relating to hospitality, gifts or expenses incurred to third parties must be submitted in accordance with the financial procedures and must specifically record the reason for the expenditure. All accounts, invoices, memoranda and any other documents and records relating to dealings with third parties must be accurately and thoroughly completed. ‘Off-book’ accounts are not permitted.

Whistle Blowing
Employees are encouraged to raise concerns about any internal issue or suspicion of malpractice at the earliest possible instance. CCT will apply criminal and administrative sanctions in a robust manner to demonstrate and remain committed to our zero tolerance policy to bribery and other illegal monetary influences.

6. Monitoring
To ensure the effectiveness its implementation, this policy will be subject to regular review in order to foster continuous improvement in both the detection and prevention of bribery or bribery-related practices.

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