Anti-bribery and corruption policy
This policy applies to anyone working for BMJ Group, or on behalf of BMJ Group, in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. It sets out what everyone must do to prevent and address bribery and corruption. It also provides information and guidance about how to recognise and deal with bribery and corruption.
You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and corruption is the responsibility of all those working for us or under our control.
What we mean by “bribery” and “corruption”
A bribe (or kickback) is a financial or other incentive or inducement that is offered, requested, promised or provided or accepted for the purpose of gaining an improper advantage. Advantages may be commercial, contractual, regulatory or personal. A bribe can include money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value. Corruption is the abuse of entrusted power or position for private gain. Expenditure without transparency or accountability will typically be corruption.
In the UK and many other parts of the world, bribery and corruption are illegal. Bribery and corruption are also unethical.
BMJ Group’s position
Zero tolerance
We have a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. We will continue to ensure that we apply the highest standards of ethical conduct and integrity in all our business activities in the UK and overseas.
Transparency
We are committed to implementing and enforcing effective systems throughout BMJ Group to ensure there is transparency in our own business and in our approach to tackling bribery and corruption throughout our supply chains.
Working with us
We expect the same high standards from all of our colleagues, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against bribery and corruption. We expect those we work with to hold their own suppliers to the same high standards.
You must not:
Give a bribe by giving, promising or offering any payment, gift, hospitality or other benefit:
- with the expectation or hope that an advantage will be received (or to reward an advantage already given); or
- to a government or public official, agent or representative to enable, facilitate or speed up a routine procedure or with the expectation or hope that an advantage will be received (or to reward an advantage already given);
Accept a bribe by accepting or requesting a payment, gift, hospitality or other benefit from a third party where you know, or suspect, that it is being offered with the expectation that it will provide an advantage for them (or anyone else) in return;
Engage in threatening or intimidating behaviour by threatening or retaliating against another worker who has refused to engage in bribery or corruption, or who has raised concerns under this policy; or
Engage in any other activity that might lead to a breach of your obligations under this policy.
What you must do
You must notify your line manager and our Director of Finance as soon as possible if you believe or suspect bribery or corruption in any part of our business or supply chain. If you are unsure whether a particular act may constitute a bribe or corruption, we encourage you to still raise it.
If, for any reason, you feel unable to speak to your line manager or the Director of Finance about your concerns, then we would encourage you to still report the matter in accordance with our Whistleblowing policy.
Gifts and hospitality
You can still give and accept reasonable and appropriate gifts and hospitality for legitimate purposes such as building and maintaining relationships, maintaining our image and reputation, or effectively presenting our products and services. You must ask yourself if the gift, entertainment or hospitality is reasonable and justifiable in the circumstances. For example:
Type/value: A gift or hospitality which is unduly lavish or extravagant will not be appropriate
Reason: Why is the gift or hospitality being given? Timing can also be an important consideration – For instance, a gift or hospitality given during contractual negotiations or a tender process will not be appropriate as it could be seen as an inducement or reward for any preferential treatment
Cash: You must never accept a gift of cash or a cash equivalent (such as vouchers)
Transparency: A gift or hospitality must never be secret
If you are offered a gift or hospitality which does not meet our requirements you must immediately report it to your line manager and our Finance Director.
Reporting gifts over £49 GBP: Any gift with a value over £49 GBP (or the local equivalent outside the UK) must be declared and approved by your line manager before it can be accepted or given. To make a declaration, please complete our Gift Register Submission Form.
When giving or receiving any gift or hospitality, you must always keep an accurate and complete record of it, including copies of any invoices and other relevant documents (such as any declarations you have made using our Gift Register Submission Form). Your records must never be kept “off-book” to facilitate or conceal payments or improper conduct.
BMJ Group’s legal obligations and commitment to you
Under the Bribery Act 2010, a criminal offence can be committed by commercial organisations which fail to prevent persons associated with them from committing bribery on their behalf. Organisations must, therefore, have adequate procedures in place to counter the risk of bribery. Further guidance about the Bribery Act 2010 and what it means for commercial organisations like BMJ Group is available here.
Individuals who refuse to accept or offer a bribe, who raise concerns, or who report another’s wrongdoing can sometimes be worried about the 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 detrimental treatment as a result of refusing to take part in bribery or corruption or reporting in good faith their suspicion that bribery or corruption is (or may be) taking place. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe you have suffered any such treatment, immediately inform Jennie Heals, Director of People and Transformation.
Communication of this policy and our requirements
Training on this policy, and on the risk our business faces from bribery and corruption in our supply chains, forms part of the induction process for everyone who works for us. All BMJ Group employees are required to complete training upon induction and, thereafter, every two years. Failure to complete the required training could result in disciplinary action.
Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of any business relationship with them and reinforced as appropriate thereafter.
Consequences of breaching this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other colleagues and organisations working on our behalf if they breach this policy.
Responsibility for this policy
Each person working for us or on our behalf (in any capacity) is responsible for ensuring that they comply with their obligations in this policy. However, the following are responsible for overseeing compliance with this policy generally and on a day-to-day basis:
Our Group Leadership Team
Has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it
Our Director of Finance
Has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.
Our management – at all levels
Are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of bribery and corruption in supply chains.
Contact us
If you have questions, comments or suggestions about this policy, please contact the Director of Finance.
