Anti-Bribery and Corruption Policy

1. Purpose

The purpose of this policy is to set out R&S Recruitment Services Ltd commitment to conducting all business in an honest, fair, and ethical manner.

R&S Recruitment Services Ltd has a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly, and with integrity in all business dealings and relationships.

This policy complies with the Bribery Act 2010 and other applicable anti-corruption laws.

2. Scope

This policy applies to:

 • All employees (permanent, temporary, and contract).

 • Directors, officers, consultants, agency workers, volunteers, interns, and secondees.

 • Any third parties acting on behalf of [Company Name], including agents, suppliers, and subcontractors.

It applies to all business activities in the UK and abroad.

3. What is Bribery?

A bribe is any offer, promise, giving, request, or acceptance of an advantage (financial or otherwise) to induce or reward improper performance of a person’s duties.

Examples include:

 • Offering money, gifts, or hospitality to influence a business decision.

 • Requesting or accepting something of value in return for preferential treatment.

 • Making “facilitation payments” to speed up routine government actions.

Bribery and corruption are criminal offences — both for individuals and the company.

4. Policy Statement

R&S Recruitment Services Ltd strictly prohibits:

 • Offering, promising, giving, or accepting bribes in any form.

 • Making facilitation or “grease” payments.

 • Offering gifts or hospitality intended to influence business decisions.

 • Engaging in any corrupt business practice.

We expect all third parties representing us to uphold these same standards.

5. Gifts and Hospitality

Reasonable and proportionate hospitality or gifts may be acceptable only if they:

 • Are for a legitimate business purpose.

 • Are of low value and not excessive.

 • Are not intended to improperly influence any decision.

 • Are fully declared and recorded in the Gifts and Hospitality Register.

Employees must seek approval from their line manager before offering or accepting any gift or hospitality.

6. Facilitation Payments and Kickbacks

R&S Recruitment Services Ltd does not make, and will not accept, facilitation payments or kickbacks of any kind.

All payments must be transparent, properly approved, and recorded in accordance with company financial procedures.

7. Charitable and Political Contributions

We may make charitable donations that are legal and ethical, but never to gain a business advantage.

R&S Recruitment Services Ltd does not make political donations.

8. Responsibilities

 • Management: Ensure implementation and communication of this policy.

 • Employees: Must understand and comply with the policy, attend training, and report any concerns.

 • Finance and Procurement Teams: Must ensure all transactions are properly documented and auditable.

9. Reporting Concerns

If you are offered a bribe, asked to make one, or suspect any form of corruption, you must report it immediately to:

 • Your line manager, or

 • The Compliance Officer / HR Department, or

 • Through the Whistleblowing Hotline (confidential reporting option).

Reports will be treated seriously, investigated promptly, and handled confidentially.

There will be no retaliation for genuine reports made in good faith.

10. Training and Communication

All employees receive anti-bribery and corruption training appropriate to their role.

This policy is available to all employees and contractors and is included in induction and refresher programs.

11. Monitoring and Review

R&S Recruitment Services Ltd regularly monitors the effectiveness of this policy through audits, risk assessments, and management reviews.

The policy will be updated as necessary to reflect changes in law or business operations.

12. Breach of Policy

Any employee found to have breached this policy will face disciplinary action, up to and including dismissal.

R&s Recruitment Services Ltd may also terminate relationships with third parties who fail to comply.

13. Policy Approval

This policy is endorsed by senior management and demonstrates our ongoing commitment to integrity and compliance.

Signed:

Sarah Morgan

Director

14/01/2025