Anti Bribery and Corruption
Policy Statement

Equality & Diversity Statement

EQ Care Group is committed to the fair treatment of all, without fear of discrimination on the grounds of age, gender, gender identity and expression, sexual orientation, marital or civil partner status, race, colour, nationality, ethnic origin, religion or belief, disability, or any other personal characteristic.

We hold ourselves to account when things aren’t quite right and take responsibility for our actions and decisions. This is so that we are able to make things right for others challenge ourselves to learn and grow as individuals as well as an organisation in order to provide consistent, safe and happy services.

Executive Summary

EQ Care Group is committed to applying the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. Every employee and individual action on EQ Care Groups behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.

Policy Statement

This policy is designed to help employees understand the stance in which EQ Care Group takes in regard bribery and corruption.

1. Introduction
2. Personal Commitments
3. Protection
4. Record Keeping
5. Responsibilities
6. Sanctions
7. Tax Treatment
8. Other Matters

1. Introduction

EQ Care Group are committed to operating a framework for the prevention and detection of fraud, bribery and corruption. We will uphold all UK legislation in order to oppose fraud, bribery and corruption, such as the Bribery Act 2010.

This policy has been designed to help employees understand the organisation’s approach to reducing and controlling the risk of fraud, bribery and corruption.

We take a zero-tolerance approach to fraud, 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 procedures to counter fraud, bribery and corruption.

This policy applies to all business practices and conduct both within the UK and overseas, including dealings with government and public bodies, their advisors, representatives and officials, politicians and political parties.

This policy applies to all employees (team members, contract and temporary), third parties and associated persons acting on our behalf.

This policy extends to all our majority owned business dealings and transactions in all countries in which we or our associates operate. Where we have a minority interest, we will encourage the application of this policy amongst our business partners including third parties, suppliers and joint venture partners.

This policy, together with any prevailing Code of Conduct which supports this policy, will be communicated to third parties and incorporated into contractual dealings.

2. Personal Commitments

• Employees are required not to put themselves in any position which might lead to, or suggest, a conflict of interest. Employees are also required not to engage in any form of otherwise unethical or unlawful behaviour.
• Certain conduct is automatically prohibited. Prohibited conduct includes facilitation payments, kickbacks, political donations and payments to Public Officials.
• Other conduct such as the giving or receiving of any advantage (whether pecuniary, financial or otherwise) such as a gift, invitation, entertainment or hospitality may be permissible depending on the circumstances. All occurrences whereby attempts have been made to give or receive (e.g. gifts, invitations etc.) should be reported immediately by the employee to their line manager.
• Any offer of a bribe must be refused and reported internally immediately. Where appropriate, any bribe will also be reported to the police and/or regulatory authorities.
• Employees are required to avoid any activity that might lead to, or suggest, a breach of the Anti-Bribery Policy.
• Employees, third parties and associates are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. For example, if a customer, distributor, or potential supplier offers something to gain an advantage with us, or indicates that a gift or payment is required to secure their business.
• Employees who are unsure whether a particular act might constitute bribery, or have any other queries, should raise a query immediately with a line manager or senior manager.
• Any concerns relating to the business practices of any employee, third party or associate (for example, if you believe or suspect that a conflict has occurred or may occur in the future) can also be reported by following the procedure set out in our Whistleblowing policy.
• Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.

3. Protection

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform a senior manager immediately.

If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure which can be found in the team handbook.

4. Record Keeping

We must keep financial records and have appropriate internal controls in place which will evidence the business reason and justification for any form of advantage received from or made to any third party.

All accounts, invoices, memoranda, and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept ‘off book’ to facilitate or conceal improper payments or any form of advantage.

5. Responsibilities

The board of directors has overall responsibility for oversight, including:

• Ensuring this policy and the procedures connected are adequate and otherwise comply with our legal and ethical obligations.
• That those under our control comply with this policy.
• Ensuring that the effectiveness of this policy is monitored and periodically reviewed.
• All employees and stakeholders have a responsibility for conducting themselves in an ethical and business-like manner at all times and reporting any concerns to management.
• Management at all levels are responsible for ensuring those reporting to them are made aware of an understand this policy and are given adequate and regular training on it.
• In conjunction with the group, the divisional and department heads are responsible for ensuring that all team members within their division or department receive relevant training.
• It is the responsibility of every manager to communicate this policy and ensure that all employees and third parties, within their area of responsibility understand, and comply with the objectives.

6. Sanctions

Any violation of this policy or anti-bribery procedures is a cause for disciplinary action, and could lead to dismissal for gross misconduct.

No employee will be penalised, or be subject to other adverse consequences for refusing to pay bribes even if it may result in losing business.

We also reserve the right to terminate our contractual relationship with third parties if they breach this policy and/or the Code of Conduct as appropriate. We will in any event report any suspicion of unlawful activity to the regulatory authorities.

7. Tax Treatment

The acceptance and giving of invitations or gifts may have tax consequences for employees, recipients and/or the employers. The use and concession of discounts and other price advantages based on contracts or master agreements that the company has entered into may likewise trigger tax consequences.  The employee will indemnify the Urban Village group for any such liability that arises.

8. Other Matters

Any act of bribery may also amount to an offence under the Fraud Act 2006. For example, falsifying documents or making false statements could amount to fraud by false representation where there is dishonest intent to make a gain on the part of an individual or another, or to cause loss to another or to expose another to a risk of loss.